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Appendix B. Environmental Assessment

CHAPTER 1. PURPOSE AND NEED FOR ACTION...................................................................... 1

Introduction............................................................................................................................................... 1

Plan Area.................................................................................................................................................... 1

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

NEPA and this Document....................................................................................................................... 3

Decisions to be Made................................................................................................................................ 4

Comprehensive Conservation Planning Process................................................................................ 4

Issues Identification............................................................................................................................... 5

Public Involvement................................................................................................................................. 5

U.S. Fish and Wildlife Service and National Wildlife Refuge System........................................... 5

Purposes of the Don Edwards San Francisco Bay National Wildlife Refuge ............................. 6

Vision Statement .................................................................................................................................... 6

Goals of the Refuge ................................................................................................................................ 7

CHAPTER 2. ALTERNATIVES, INCLUDING THE PREFERRED ALTERNATIVE ........... 8

Current Management............................................................................................................................... 8

Alternatives Development Process........................................................................................................ 8

Features Common to All Alternatives.................................................................................................. 9

Alternatives Considered but Eliminated from Detailed Analysis ................................................ 10

Preferred Alternative............................................................................................................................. 11

Description of Management Alternatives.......................................................................................... 12

Alternative A: No Action .................................................................................................................... 12

Alternative B: moderate increase in wildlife management, habitat management, visitor 

services, and the environmental education program........................................................................ 14

Alternative C: same as B; and substantial increase in wildlife management, habitat 

management, visitor services, and the environmental education program. .................................. 19

CHAPTER 3. AFFECTED ENVIRONMENT ................................................................................. 39

CHAPTER 4. ENVIRONMENTAL CONSEQUENCES................................................................ 40

Physical Resources................................................................................................................................. 40
Hydrology ............................................................................................................................................. 40

Water Quality and Contaminants....................................................................................................... 42

Soils and Topography .......................................................................................................................... 44

Air Quality............................................................................................................................................. 47

Hazardous Materials and Safety Issues ............................................................................................ 48

Wilderness............................................................................................................................................. 49

Biological Resources.............................................................................................................................. 50

Vegetation and Habitat........................................................................................................................ 50

Wildlife................................................................................................................................................... 54

Fish and Marine Invertebrates .......................................................................................................... 69

Endangered Species............................................................................................................................. 70

Social and Economic Environment.................................................................................................... 77

Recreation ............................................................................................................................................. 77

Economy................................................................................................................................................ 78

Cultural Resources............................................................................................................................... 82

Climate Change .................................................................................................................................... 83

Environmental Justice........................................................................................................................... 86

Cumulative Effects................................................................................................................................. 86

Cumulative Effects on the Physical Environment ........................................................................... 89

Cumulative Effects on Biological Resources..................................................................................... 89

Cumulative Effects on Cultural Resources ....................................................................................... 90

Cumulative Effects on the Social and Economic Environment ...................................................... 91

CHAPTER 5. LIST OF PLANNING TEAM MEMBERS AND PERSONS RESPONSIBLE 

FOR PREPARING THIS DOCUMENT ............................................................................................ 94

CHAPTER 6. COORDINATION, CONSULTATION, AND COMPLIANCE............................. 95

Agency Coordination and Public Involvement................................................................................. 95

Notice of Intent....................................................................................................................................... 95

Environmental Review and Consultation ......................................................................................... 95

Other Federal Laws, Regulations, and Executive Orders.............................................................. 95

Distribution and Availability ............................................................................................................... 95

REFERENCES....................................................................................................................................... 96

TABLES

Table 1. Summary of Alternatives ......................................................................................................... 21

Table 2. Pesticides and Herbicides Used on the Refuge..................................................................... 49
Table 3. Estimated Annual Refuge Visitation by Visitor Activity for Alternatives A, B, and C. ... 80

Table 4. Economic Impacts of the Refuge Management Activities for Alternative A..................... 81

Table 5. Economic Impacts of the Refuge Management Activities for Alternative B..................... 81

Table 6. Economic Impacts of the Refuge Management Activities for Alternative C...................... 82

Table 7. Predicted Loss Rates of Land Categories by 2100 Given Simulated.................................. 84

Table 8. Summary Impacts of Alternatives .......................................................................................... 91

FIGURES

Figure 1. Don Edwards San Francisco Bay National Wildlife Refuge (NWR).................................. 2

Figure 2. Alternative B - Reduced Access for Dog Walking .............................................................. 18

Figure 3. Visitor Service and Environmental Education Activities for Alternative A .................... 36

Figure 4. Visitor Service and Environmental Education Activities for Alternative B .................... 36

Figure 5. Visitor Service and Environmental Education Activities for Alternative C .................... 37

APPENDICES

A Regional Economic Impacts of Current and Proposed Management Alternatives for Don 

Edwards National Wildlife Refuge
Glossary of Terms and Acronyms

Bay San Francisco Bay

CCG Contra Costa goldfield 

CCP Comprehensive Conservation Plan

CDFG California Department of Fish and Game

CLRA California clapper rail

CTS California tiger salamander 

EA Environmental Assessment

EEC Environmental Education Center

EIR Environmental Impact Report

EIS Environmental Impact Statement

EO Executive Order

GIS Geographic Information System

I&M Inventory and Monitoring

IMPLAN Impact Analysis for Planning

NEPA National Environmental Policy Act

NWR National Wildlife Refuge

NWRS/Refuge System National Wildlife Refuge System

PUP Pesticide Use Proposal

Refuge Don Edwards San Francisco Bay National Wildlife Refuge

RLGIS Refuge Lands Geographic Information System

SBSPRP South Bay Salt Pond Restoration Project 

SCVWD Santa Clara Valley Water District

SLAMM Sea-Level Affecting Marsh Model

SMHM salt marsh harvest mouse

USDA U.S. Department of Agriculture

USFWS/Service U.S. Fish and Wildlife Service

VPTS Vernal pool tadpole shrimp

1997 Improvement Act The National Wildlife Refuge System Improvement Act of 1997
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Chapter 1. Purpose and Need for Action

Introduction

This environmental assessment (EA), in accordance with the requirements of the National 

Environmental Policy Act (NEPA), evaluates the environmental effects of three alternatives for 

managing the Don Edwards San Francisco Bay National Wildlife Refuge (Refuge) as presented in 

the draft Comprehensive Conservation Plan (CCP). The purpose of the CCP (also referred to as 

the Plan) is to provide a 15-year management plan for the Refuge and long-term guidance in 

relation to management decisions, as directed by the National Wildlife Refuge System 

Improvement Act of 1997 (1997 Improvement Act). Both direction and guidance are described in 

detail through a set of goals, objectives, and strategies in the CCP.

Plan Area

The Refuge surrounds the southern end of the San Francisco Bay Estuary. This subregion of the 

Estuary is also called South San Francisco Bay (Bay). The lands and waters included within the 

Refuge consist of portions of the urban communities of San Lorenzo, Hayward, Union City, 

Fremont, Newark, Milpitas, San Jose, Sunnyvale, Mountain View, East Palo Alto, Menlo Park, 

and Redwood City. The Refuge is located in a highly urbanized area with access from Interstate 

Highway 880, U.S. Route 101, California State Route 237, and California State Route 84. The 

Refuge is an important stopping point for migratory waterfowl, shorebirds, and songbirds. There 

are several threatened and endangered species present on the Refuge, including the Contra Costa 

goldfield (CCG), vernal pool tadpole shrimp (VPTS), California tiger salamander (CTS), California 

least tern, western snowy plover, California clapper rail (CLRA), and salt marsh harvest mouse

(SMHM), that rely on the Refuge habitat for all or a portion of their lifecycles. 

Proposed Action

The Service proposes to implement a CCP that best achieves the purposes for which the Refuge 

was established, helps fulfill the mission of the National Wildlife Refuge System (NWRS), is 

consistent with sound fish and wildlife management, and ensures that the biological integrity, 

diversity, and environmental health of the Refuge System are maintained. 

The Service examined a range of management alternatives. A description of these alternatives is 

contained in Chapter 2. Alternative B represents the Service’s proposed action for the Refuge; 

however, the final decision can be any of the alternatives and may reflect a modification of certain 

elements of any alternative based on consideration of public comment. Of the alternatives 

evaluated, Alternative B appears to best achieve the purpose, vision, and goals for the Refuge, 

while also appropriately addressing the major issues and relevant mandates identified for the 

Refuge during the development of the CCP. 
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Figure 1. Don Edwards San Francisco Bay National Wildlife Refuge (NWR) 

Purpose and Need for the Proposed Action

A CCP is needed to provide guidance for conducting general Refuge operations, wildlife and 

habitat management, habitat enhancement and restoration, cultural resource management, and 

visitor services. The CCP is intended to ensure that management actions are consistent with the 

purposes for which the Refuge was established, the mandates of the Refuge System, and the 
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Refuge’s goals and objectives. The purpose of the CCP is to describe the desired future 

conditions of the Refuge over the next 15 years and provide guidance for achieving those 

conditions. The CCP accomplishes the following:

• Sets a long-term vision for the Refuge;

• Establishes management goals, objectives, and strategies for the Refuge;

• Provides the Refuge with a 15-year management plan for the conservation of fish, wildlife, 

and plant resources and their related habitats;

• Defines compatible public uses; 

• Develops a plan that, when fully implemented, will achieve Refuge purposes, help fulfill 

the mission of the System, and maintain and, where appropriate, restore ecological 

integrity; 

• Communicates the Service’s management priorities for the Refuge to the public; and 

• Provides a basis for budget needs to support staffing, operations, maintenance, and capital 

improvements.

The development of this CCP is also required to fulfill legislative obligations of the Service. The 

National Wildlife Refuge System Administration Act of 1966, as amended by the 1997 

Improvement Act, requires that every refuge or related complex of refuges have a CCP in place 

within 15 years of the Improvement Act’s enactment. In order to comply with NEPA, an EA or 

Environmental Impact Statement (EIS) that evaluates the effects of different alternatives 

meeting the Refuge goals must be prepared to accompany the CCP. The Draft CCP and its 

appendices are herein incorporated by reference. 

NEPA and this Document

NEPA requires Federal agencies to consider the environmental effects of all actions1 they 

undertake. This EA evaluates the effects of various alternative management scenarios for the 

Refuge. Federal agencies must also consider the environmental effects of the Proposed Action 

and a reasonable range of alternatives, then disclose those effects to the public. If adverse 

environmental effects are identified, NEPA requires an agency to identify means to mitigate the 

adverse effects. An EA documents that an agency has considered and addressed all these issues. 

This EA has been prepared to assess the environmental effects of the action alternatives. The 

U.S. Fish and Wildlife Service (Service) will also use this EA to solicit public involvement in the 

Refuge planning process, as well as determine whether the CCP will have a significant effect on 

the quality of the human environment.

This EA discusses the purpose and need for the Refuge CCP; it also provides an analysis of the 

impacts that could be expected from each of the management proposals outlined in the Plan. This 

analysis will help the Service determine if it will need to prepare an EIS or a Finding of No 

Significant Impact (FONSI) regarding the preferred alternative for the Refuge.

The policies of the Service, the 1997 Improvement Act, and NEPA require the Service to actively 

seek public involvement in the preparation of environmental documents. NEPA also requires the 

Service to give serious consideration to all reasonable alternatives for managing refuges, including 

the no-action alternative representing continuation of current conditions and management 

 

1 Under NEPA and implementing regulations, action refers to a policy, plan, program, or project that is 

implemented, funded, permitted, or controlled by a Federal agency or agencies.
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practices. Alternative management scenarios were developed as part of the planning process 

described in this EA.

This EA describes the existing resources on the Refuge and the projected environmental effects

of the three management alternatives. Two of the three alternatives presented in this EA are 

action alternatives that would involve a change in the current management of the Refuge. The 

remaining alternative is the no-action alternative, under which current management of the 

Refuge would continue, and provides a basis of comparison to the action alternatives. A final CCP 

will be prepared regardless of which alternative is selected.

Decisions to be Made

Based on the analysis documented in this Draft EA, the Regional Director must determine the 

type and extent of management and visitor service opportunities on the Refuge as well as, 

whether the selected management alternative would have a significant effect on the quality of the 

environment. If the selected alternative has no significant impacts, then the Service would 

prepare a FONSI. If the proposed management alternative is found to have significant impacts, 

then the Service would prepare an EIS before making a decision. 

The planning team has recommended Alternative B for implementation. The Service will make a 

final selection of an alternative to implement in the CCP, based on this document and the input 

received from the public during the comment process. The Plan will be monitored annually and 

revised when necessary.

Comprehensive Conservation Planning Process

The Service developed the CCP using a systematic decision-making approach that encouraged 

public involvement in management decisions throughout the planning process. A planning team 

was assembled (see Chapter 5) of personnel from the Service’s San Francisco Bay National 

Wildlife Refuge Complex. The Service contacted a wide range of people to participate, including 

representatives of Federal agencies, Congress, State officials, State conservation agencies, 

conservation organizations, local interest groups, and other members of the public. These 

interested participants and local residents received announcements regarding the location, date, 

and time for the initial scoping meeting. At the scoping meeting, the staff explained the Refuge’s 

purpose, history, and laws and regulations governing management, as well as the purpose and 

need for the CCP and the relevant management activities and issues.

The planning team consisted primarily of Refuge staff, Service technical experts, and other 

landowners of the Refuge (some Refuge lands are managed by the Service but owned by other 

public agencies). The team developed a list of issues and concerns that included comments 

generated from the scoping meeting, written comments, and verbal comments from discussions 

with various parties. The planning team reviewed the current Refuge management actions during 

the planning process and ultimately presented three alternatives for future Refuge management.

Key steps in the Service’s comprehensive conservation planning are listed below:

1. Preplanning.

2. Identifying issues and developing a vision statement.

3. Gathering information.

4. Analyzing resource relationships.
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5. Developing alternatives and assessing environmental effects.

6. Identifying a preferred alternative.

7. Publishing the draft plan and NEPA document.

8. Addressing public comments on the draft plan.

9. Preparing the final plan.

10. Securing approval from the Regional Director.

11. Implementing the plan.

Issues Identification

The Service followed NEPA scoping guidelines and identified issues, concerns, and opportunities 

through early planning discussions and the public scoping process, which began in the fall of 2009. 

The planning team identified a range of reasonable alternatives, evaluated the consequences of 

each alternative, and identified a preferred alternative for guiding the Refuge’s future direction. 

This planning effort and the planning team’s ongoing dialogue with various Federal, State, and 

county agencies; interest groups; and individuals provided important direction in synthesizing the 

proposed goals, objectives, and strategies found in the draft CCP. It will be necessary to further 

coordinate and cooperate with these entities to implement the Plan. 

Public Involvement 

Public involvement is an essential component of the comprehensive conservation planning and 

NEPA process. The Service announced the beginning of this planning effort for the Refuge 

through a Federal Register Notice of Intent on February 23, 2010. The Service sent individual 

letters announcing commencement of the planning process to several local organizations, the local 

city government, congressional members, State officials, State agencies, interested parties, and 

conservation organizations. In 2009, the Refuge hosted a series of public meetings on October 28, 

November 3, and November 5. Public comments were generated from the public meetings, and 

the Federal Register notice was published on February 23, 2010. A planning update, which 

introduced the Refuge and the planning process, was mailed to over 200 agency and organization 

representatives, members of the public, media, and elected representatives of each of the counties. 

An average of 10 people attended each of the meetings. A number of individuals provided 

comments at the meetings, via email, and by postal mail. The Refuge hosted another series of 

public meetings on April 13, 2011, and April 19, 2011, to present management alternatives. An 

average of 15 people attended each of these meetings.

Written public input received during the process is incorporated into the CCP and EA when 

feasible, and a summary of the comments is presented in the CCP. The original comments are 

maintained in planning team files at the San Francisco Bay National Wildlife Refuge Complex 

headquarters in Fremont, California, and are available for review.

U.S. Fish and Wildlife Service and National Wildlife Refuge System

The mission of the Service is working with others to conserve, protect, and enhance the Nation’s 

fish and wildlife and their habitats for the continuing benefit of the American people. The Service 

is the primary Federal agency responsible for migratory birds, endangered plants and animals, 

certain marine mammals, and interjurisdictional fish. This responsibility to conserve the Nation’s 

fish and wildlife resources is shared with other Federal agencies as well as with State and tribal 

governments.
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As part of this responsibility, the Service manages the NWRS. The Refuge System is the only 

nationwide system of Federal lands managed and protected for wildlife and their habitats. The 

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

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

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

generations of Americans. The Refuge is managed as part of the Refuge System in accordance 

with the National Wildlife Refuge System Administration Act of 1966 as amended and other 

relevant legislation, executive orders, regulations, and policies.

Purposes of the Don Edwards San Francisco Bay National Wildlife Refuge 

Refuges are not only guided by the Service and NWRS missions, but also individual purposes that 

form the authority for the establishment of a Refuge. These purposes are often drawn from 

Federal acts or executive orders. Further, these purposes provided the foundation for which the 

Refuge vision statement and the CCP goals have been developed. Don Edwards San Francisco

Bay NWR was established under the following authorities: 

86 Stat. 399, dated June 30, 1972 – “... for the preservation and enhancement of highly significant 

wildlife habitat ... for the protection of migratory waterfowl and other wildlife, including species 

known to be threatened with extinction, and to provide an opportunity for wildlife-oriented 

recreation and nature study....”

An Act Authorizing the Transfer of Certain Real Property for Wildlife, or other purposes (16 

U.S.C. 667b) – “... particular value in carrying out the national migratory bird management 

program.” 

Endangered Species Act of 1973 (16 U.S.C. 1534) – “... to conserve (A) fish or wildlife which are 

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

Fish and Wildlife Act of 1956 (16 U.S.C. 742f) – “... for the development, advancement, 

management, conservation, and protection of fish and wildlife resources...” 16 U.S.C. § 742f(a)(4) 

“... for the benefit of the United States Fish and Wildlife Service, in performing its activities and 

services. Such acceptance may be subject to the terms of any restrictive or affirmative covenant, 

or condition of servitude ...” 16 U.S.C. § 742f(b)(1).

Vision Statement

The Don Edwards San Francisco Bay National Wildlife Refuge was born out of the foresight and 

perseverance of conservation-minded individuals who recognized the unique landscape of the 

South San Francisco Bay. As part of the larger San Francisco Estuary, a site of hemispheric 

importance for shorebirds and waterfowl, the Refuge protects and restores almost 30,000 acres of 

some of the last remaining tidal marsh, mudflat, open bay, vernal pool, grassland, and upland 

habitats in the South San Francisco Bay. Within an area of intense urban development, we will 

strive to restore, acquire and protect additional lands to create a functioning ecosystem of diverse 

habitats that will support healthy populations of migratory birds, endangered wildlife, and other 

native plant and animal species. Through management and restoration of these habitats, we will 

also aid in the recovery of a number of listed and sensitive species that depend on Refuge lands for 

their continued existence, including the California clapper rail, salt marsh harvest mouse, vernal 

pool tadpole shrimp, and Contra Costa goldfields. 
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To promote the conservation legacy of this Refuge, we will provide wildlife-oriented recreation, 

environmental education, and interpretation to foster public stewardship, increase appreciation, 

and encourage community involvement in the conservation of the Estuary. 

Goals of the Refuge

Refuge goals were developed on the basis of four themes: wildlife management, habitat 

management, compatible wildlife-oriented recreation, and environmental education and outreach. 

Goal 1

Protect and contribute to the recovery of endangered, threatened, and special status species on 

the Refuge by conservation and management of the habitats on which these species depend. 

Goal 2 

Conserve, restore, enhance, create, and acquire habitats to support the diversity and abundance 

of migratory birds and other native flora and fauna that depend on Refuge lands.

Goal 3

Provide the local community and other visitors with compatible wildlife-oriented outdoor 

recreation opportunities to enjoy, understand, and appreciate the resources of the Refuge.

Goal 4

Through diverse environmental education, interpretation, and outreach opportunities, increase 

public awareness of the Refuge’s purpose and the ecosystem of San Francisco Bay Estuary and 

promote environmental stewardship and conservation.

Goal 5 

Instill community stewardship through volunteerism to support the Refuge’s diverse purposes.
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Chapter 2. Alternatives, Including the Preferred Alternative

This chapter describes three alternatives for managing the Refuge: Alternative A (No Action, 

current management), Alternative B, and Alternative C. These alternatives are described below 

and summarized in Table 1 at the end of this chapter. Some of the visitor service and 

environmental education alternatives (not all actions have been designated a location and 

therefore could not be depicted) are also depicted in Figure 2, Figure 3, and Figure 4 at the end of 

this chapter. All proposed alternatives considered in this EA were developed with the mission of 

the Refuge System and the purposes of the Refuge as guiding principles. Two of the three 

alternatives presented in this chapter are “action alternatives” that would result in a change to the 

current management of the Refuge. The Service’s preferred alternative is Alternative B. 

Current Management

The Refuge currently has no integrated plan to guide the management of all its resources and 

uses. Current management efforts on the Refuge focus on monitoring endangered species, 

monitoring non-native and invasive plants, habitat restoration, environmental education, and 

public uses. 

For a complete description of the current management practices, please see Chapter 4, Current 

Refuge Management and Programs, of the CCP.

Alternatives Development Process

Three alternatives were developed to manage Don Edwards San Francisco Bay NWR. 

• Alternative A: current management (no action). 

• Alternative B: moderate increase in wildlife management, habitat management, visitor 

services, and the environmental education program. 

• Alternative C: substantial increase in wildlife management, habitat management, visitor 

services, and the environmental education program.

The alternatives development process was an iterative process that began after the planning team 

developed the Refuge vision statement and revised the Refuge’s goals. The first step in this 

process was to identify all the important issues related to Refuge management. The list of needs 

and issues was generated collaboratively by the core planning team, Service staff, and Refuge 

stakeholders. The public also helped to identify important management needs and issues through 

the scoping process.

Once the list of important management issues was generated, the planning team defined

Alternative A (no action). It was important to describe this alternative accurately because the noaction alternative serves as the baseline to compare against all other alternatives.

Next, the planning team listed a wide range of management actions that would address the issues 

identified and achieve one or more of the Refuge goals. These actions were refined during several 

meetings and planning team reviews. The planning team then clustered these into action 

alternatives to increase biological and visitor service activities. Many actions are common to more 

than one alternative, but the actions within each alternative reflect a common management 

approach, as described in detail below.
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Features Common to All Alternatives

There are a number of management components that are common to all the alternatives and 

would be part of the CCP regardless of the alternative selected for implementation. To reduce 

repetition in the alternatives descriptions, those features that are common among all of the 

alternatives are described in detail as follows. 

Endangered Species Survey and Monitoring. All proposed alternatives involve some level of 

monitoring for endangered species, particularly the CLRA and the SMHM. Research studies 

relevant to management needs will be encouraged and supported.

Other Wildlife Management. Annual monitoring of shorebirds and waterfowl are conducted with 

partners throughout the San Francisco Bay Estuary. The Refuge oversees a variety of managed 

ponds at different water levels for a variety of bird species. Nesting habitat (e.g., islands) is 

created wherever possible. The Refuge responds to wildlife disease outbreaks that occur and 

contaminants monitoring is conducted opportunistically through partners. Research studies 

relevant to management needs occur when available through partnerships and grant funding.

Predator Management. All proposed alternatives involve some level of predator management. 

Certain native and non-native animal species are controlled by U.S. Department of Agriculture 

(USDA) Wildlife Services because they are a threat to the Refuge’s trust species.

Mosquito Control. Mosquito control activities are coordinated and conducted with the Alameda, 

Santa Clara, and San Mateo County Mosquito Abatement Districts. 

Vegetation Management. All the alternatives prescribe some level of monitoring, response, and 

prevention of the spread of non-native and invasive vegetation. The Refuge works with partners 

to actively monitor and control (through manual and chemical methods) invasive Spartina

(cordgrass). Mapping of invasive pepperweed would be conducted under all alternatives. Some 

level of invasive weed control is conducted under all the alternatives through mechanical, cultural 

(e.g., grazing), thermal (i.e., burning), and chemical methods. The Refuge conducts native plant 

propagation at its nurseries and habitat restoration occurs through support from partners, 

volunteers, and school groups. 

Tidal Marsh Restoration. Some tidal marsh restoration activities were planned prior to the CCP 

process (e.g., South Bay Salt Pond Restoration Project [SBSPRP] and the Bair Island 

Restoration Project). The restoration of additional diked wetland areas to tidal influence will 

continue.

Acquisition. The Refuge has continually acquired lands within the approved acquisition boundary 

that meet the Refuge purposes from willing sellers when refuge resources allow. 

Public Uses. The Refuge provides opportunities for wildlife observation, photography, hunting, 

fishing, and interpretation. Some levels of all these activities are prescribed for each alternative. 

Waterfowl hunting is permitted on the Refuge per state regulations. A number of non-wildlife 

dependent recreational opportunities facilitate or occur in conjunction with wildlife observation, 

photography, hunting, fishing, and interpretation; these opportunities include hiking, dog-walking 

(at the headquarters), bicycling (on approved trails), boating, and a geocaching program. 
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Environmental Education. The Refuge conducts a wide range of environmental education 

programs that focus on primary themes of wetland conservation, habitat restoration, and 

watershed and water quality protection. A number of special environmental education events are 

also conducted to promote the Refuge’s mission, including the South Bay Bird Festival, Spooky 

Slough, and Shark Day.

Cultural Resources. Cultural resource surveys are conducted opportunistically when projects 

occur. All cultural resource site locations are kept confidential. Cultural resources are managed 

in accordance with public law and agency policy. Any unknown cultural resources found during 

any ground disturbance or projects affecting historic structures on the Refuge would be assessed 

by Service cultural resources staff to determine potential impacts and compliance with applicable 

Federal laws and executive orders. For any major ground disturbing projects, the Refuge would 

consult with the State Historic Preservation Office (SHPO), federally recognized Tribes, and 

interested parties, when appropriate.

Facilities Maintenance. General maintenance of existing facilities, including mechanical control 

of vegetation; inspection, repair, rehabilitation, or replacement of infrastructure and equipment 

(e.g., fencing and signage); and oversight of safety of operations, is required on the Refuge to 

provide safe access for staff, researchers, law enforcement activities, educational field trips, and 

the public. Upland areas require mowing to reduce fire hazards, provide non-native weed control, 

and provide access for maintenance, monitoring, and restoration/enhancement projects. The 

Refuge’s headquarters site, Environmental Education Center, water control structures, levees, 

and trails require frequent maintenance and repair.

Law Enforcement and Resource Protection. Law enforcement on the Refuge safeguards the 

public, staff, facilities, and natural and cultural resources from criminal action, accidents, 

vandalism, and negligence. 

Alternatives Considered but Eliminated from Detailed Analysis

The alternatives development process under NEPA and the Improvement Act are designed to 

allow the planning team to consider the widest possible range of issues and develop feasible 

management solutions that respond to these issues. These management solutions are then 

incorporated into one or more alternatives evaluated in the EA process and considered for 

inclusion in the CCP.

Actions and alternatives that are not feasible or may cause substantial harm to the environment 

are usually not considered in an EA. Similarly, an action (and therefore, an alternative containing 

that action) should generally not receive further consideration if:

• It is illegal (unless it is the No Action Alternative, which must be considered to provide a

baseline for evaluation of other alternatives, even though it may not be capable of legal 

implementation).

• It does not fulfill the mission of the National Wildlife Refuge System.

• It does not relate to or help achieve one of the goals of the Refuge.

• Its environmental impacts have already been evaluated in a previously approved NEPA 

document.

However, if such actions or alternatives address a controversial issue or an issue on which many 

public comments were received, they may be considered within detail in a NEPA document to 
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demonstrate clearly why they are not feasible or would cause substantial harm to the 

environment.

During the alternatives development process, the planning team considered a wide variety of 

potential actions on the Refuge. The following actions were ultimately rejected and excluded from 

the proposed alternatives because they did not achieve Refuge purposes or were incompatible 

with one or more goals.

Closing Hunting on Mowry Ponds. The Refuge staff considered closing the Mowry Ponds to 

potentially increase protection to wetlands. However, after consulting with hunters, the use at the 

ponds was considered low volume and thus impacts to vegetation and wildlife also low. This 

discussion resulted in no change to the Mowry Pond hunting area. 

Entry Point at Mowry Ponds. The Refuge staff considered limiting access to the Mowry Ponds to 

a designated entry point in order to reduce trampling of vegetation by boat and foot traffic, as well 

as reduce wildlife disturbance. However, after consulting with hunters, the use at the ponds was 

considered low volume and thus impacts to vegetation and wildlife also low. 

Opening Additional Ponds to Hunting. The Refuge staff considered opening Ponds A20, A21, 

and A2W to hunting. After analyses regarding wildlife considerations, it was decided that these 

ponds remain closed to provide waterfowl resting areas.

Close Faber-Laumeister Access. The Refuge staff considered closing the middle levee of the 

Faber-Laumeister subunit to public access. It was thought that closing access would reduce 

disturbance to the levee, which tidal marsh species in the area (e.g., CLRA) use for high tide 

refugia. After feedback from local community representatives and local officials, public access 

would remain open to the subunit. It was also decided that when funds become available, a raised 

boardwalk would be constructed on the levee to provide a barrier between the public and the 

sensitive transition zone to the tidal marsh.

Preferred Alternative

The planning policy that implements the Improvement Act requires the Service to select a 

preferred alternative, which is also the preferred alternative under NEPA. The complete written 

description of this preferred alternative is Chapter 5: Refuge Management Direction of the Draft 

CCP. Alternative B is the preferred alternative for the Refuge because it meets the following 

criteria:

• achieves the mission of the National Wildlife Refuge System; 

• achieves the purposes of the Refuge; 

• provides guidance for achieving the Refuge’s 15-year vision and goals; 

• maintains and restores the habitats and populations on the Refuge; 

• addresses the important issues identified in the scoping process; 

• addresses the legal mandates of the Service and the Refuge; and

• is consistent with the scientific principles of sound fish and wildlife management and 

endangered species recovery. 

The preferred alternative described in the EA is preliminary. The action ultimately selected and 

described in the Final CCP will be determined, in part, by the comments received on the Draft 

EA. The preferred alternative presented in the Final CCP may suggest a modification of one of 
B-12

the alternatives presented here. The three alternatives considered for managing the Refuge are 

summarized in Table 1 and are described as follows. 

Description of Management Alternatives

Alternative A: No Action

Under this alternative, the Refuge would continue current management actions, including habitat 

management, wildlife management, wildlife-oriented opportunities, and environmental education. 

Habitat and wildlife management activities would emphasize habitat restoration projects, invasive 

weed management, wildlife surveys, and predator management. A wide variety of wildlifeoriented opportunities would continue to be offered. The environmental education program would 

continue to conduct a variety of topics. A few non-wildlife dependent recreational opportunities 

would continue to be permitted. Also, the volunteer program that supports the biology, visitor 

services, environmental education, and management needs of the Refuge would continue. Current 

staffing and funding would remain the same. The Refuge would continue to implement existing 

restoration and management plans (e.g., Bair Island Restoration and Management Plan and 

SBSPRP). The Refuge would also actively work with partners and willing sellers to acquire the 

remaining lands within the approved acquisition boundary.

Listed Species. Under Alternative A, annual CLRA surveys would continue to be conducted 

within a subset of the Refuge. Opportunistic surveys for the SMHM would also be conducted. 

Vernal pool surveys to determine presence of CTS, VPTS, and CCG would also continue. The 

Refuge would continue to work with partners to monitor and research the western snowy plover. 

Predator management of mammals would be conducted to protect and reduce threats to listed 

species. Sporadic restoration (through partners) of the ecotone/transition zone would increase 

high-tide refugia for listed species. Tidal restoration activities under this alternative would also 

benefit listed species.

Other Species. Under Alternative A, biological monitoring would continue, including waterfowl 

and shorebird surveys with partners on an annual basis by ground and aerial surveys. Tidal 

restoration activities under this alternative would benefit a variety of species. Mammalian 

predator management (e.g., red fox control) would also continue to benefit wildlife resources. The 

Refuge would carry on support of fish, migratory bird, and other wildlife monitoring and research 

through its partners. Intermittent weed management activities would also continue to the benefit 

of wildlife resources. Vernal pool vegetation and upland grassland surveys would continue to be 

conducted to provide input on management to benefit native species. Ponds would remain

managed at different water levels to support shorebirds and wildlife. The Refuge staff would 

continue to respond to botulism and other outbreaks to recover wildlife resources.

Habitat Management. Under Alternative A, the Service would continue to manage the habitat on 

the Refuge as described in detail in Chapter 4 of the CCP. The primary habitat types managed 

are vernal pool grassland, ecotone/transition zone, managed ponds, and tidal and managed marsh. 

Managed ponds and marsh would continue to be restored as appropriate to improve tidal 

connectivity and restore marsh vegetation. Water levels in the remaining managed ponds would 

be operated to support a variety of shorebirds and waterfowl. Grazing and prescribed burning 

would continue to be used to reduce biomass of residual dry matter. Sporadic weed control and 

revegetation of the ecotone/transition zone would carry on as funds permit. Spartina control 

would continue to be conducted through partners, and intermittent control of pepperweed and 
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other priority weeds would be conducted as funds and staffing permit. Volunteers would maintain

support of habitat restoration through manual weed removal, plant propagation at the Refuge and 

partner nurseries, planting native vegetation on the Refuge, and conducting non-native vegetation 

surveys.

There is a long history of mosquito management throughout the San Francisco Bay region given 

the large human population in the area. Per public health protection, mosquito control on the 

Refuge is an existing use conducted by the Alameda, Santa Clara, and San Mateo Mosquito 

Abatement Districts. Mosquito management activities involve mosquito population monitoring, 

disease surveillance, and habitat improvements (e.g., wetland enhancements, ditching). The 

Refuge would continue to work with these mosquito abatement districts to manage the threat of 

mosquito-borne disease on the Refuge through physical, biological, and chemical methods. Use of 

larvicide, pupacide, and adulticide is coordinated between the districts and the Refuge when 

mosquito populations and/or mosquito-borne diseases are detected on or within flight range of the 

Refuge.

Acquisition. The Refuge would continue to acquire lands within the approved acquisition 

boundary that meet the Refuge purposes from willing sellers when refuge resources allow. 

Public Access. Under Alternative A, the Refuge would continue to provide hunting, fishing, 

wildlife observation, wildlife photography, and interpretation as detailed in Chapter 4 of the CCP. 

Under this alternative, waterfowl hunting would continue to be allowed in several ponds 

surrounding the South Bay. Approximately 7,500 acres of the 30,000 acres on the Refuge are open 

to waterfowl hunting. This acreage includes managed ponds, tidal areas, and the open Bay. All 

Refuge hunting areas are generally accessible by boat only. All hunting on the Refuge must 

comply with State and Federal Regulations. In order to conduct the hunt program (e.g., provide 

improvements to hunt blinds, hunt access, and outreach and education materials), an annual 

waterfowl hunt fee program would be developed. 

Fishing would also continue to be permitted on the Refuge by boat, from the pier at the Refuge 

headquarters, the shoreline of the Faber-Laumeister subunit, and at Coyote Creek Lagoon. The 

public fishing pier is located at the end of Marshlands Road and is open year-round. However, 

birds, particularly the threatened western snowy plover, occasionally nest along Marshlands 

Road. From April 1 through August 31, when nesting birds are found, Marshlands Road is closed 

to public vehicle traffic. When the closure is in effect on weekends, public access to the fishing 

pier is via free shuttle service. As a designated “Public Fishing Pier,” no fishing license is needed 

at this location. The Refuge would also conduct an annual fishing day event held at the fishing 

pier in the headquarters location. 

Wildlife observation, photography, and interpretation would continue to be facilitated by more 

than 30 miles of trails, access sites, overlooks, a visitor center, more than 200 guided opportunities, 

self-guided interpretative opportunities, and some visitor contact services at the Environmental 

Education Center. The Refuge would also continue to offer special events under this alternative, 

such as an Earth Day Cleanup and an Endangered Species Poster Contest.

Environmental Education. Under this alternative, the Refuge would continue providing a 

comprehensive environmental education program. The Program serves over 10,000 students 

annually through a variety of programs, including Wetland Round-up, Restoration Education, 
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Summer Camp, Slow the Flow, Scout Program, and the Santa Clara Valley Urban Runoff 

Pollution Programs. 

Other. Under Alternative A, other non-wildlife dependent recreational uses would continue, 

including a geocache program, dog-walking, jogging, hiking, bicycling, and boating in order to 

facilitate priority public uses (i.e., wildlife observation, photography, hunting, fishing, and 

interpretation). The uses are permitted in designated areas on the Refuge. Dog walking, a use 

that has occurred for several decades, will continue to be permitted on the Tidelands (including 

the Pumphouse Trail), Harrier Spur, and Quarry Trails of the Refuge, which are all located at the 

Fremont headquarters. Dogs are also permitted on Marshlands Road, which is owned by 

Caltrans. Staff participates in a variety of off-site outreach events annually. Additionally, the 

staff conducts outreach via its Tideline newsletter, Web site, television and video, Facebook, and 

audio tours. 

Law enforcement would continue to be provided through the San Francisco Bay National Wildlife 

Refuge Complex. The Refuge also coordinates a comprehensive volunteer program to support 

biology, visitor services, and management needs.

Alternative B: moderate increase in wildlife management, habitat management, visitor 

services, and the environmental education program (preferred alternative). 

Alternative B includes those actions in Alternative A; in addition, the Refuge would moderately 

expand biological, habitat management, visitor service, and environmental education activities. 

Additional biological activities include increased survey efforts on priority listed species as well as 

baseline surveys on native focal flora and fauna (biologists would prioritize what native species to 

survey). Habitat would be improved for the western snowy plover and California least tern. 

Other habitat management activities include implementation of a comprehensive weed 

management plan, additional improvement to tidal marsh areas, restoring the ecotone/transition 

zone, and addressing climate change impacts on Refuge resources. The Service’s “Big 6” public 

uses—wildlife observation, photography, hunting, fishing, interpretation, and environmental 

education—would all be enhanced on the Refuge. Refuge staff would expand the volunteer 

program to recruit new volunteers and provide additional learning opportunities to existing 

volunteers. Additional staff and funding would be needed to implement this alternative.

Listed Species. Under Alternative B, SMHM surveys would be conducted annually within a 

subset of the Refuge. The monitoring plan for listed species would be revised to standardize 

protocols. Nest site enhancement, additional management actions, and monitoring would be 

conducted to increase western snowy plover productivity. The Refuge would also survey and 

monitor several listed plant species, including the Suisun thistle, salt marsh bird’s-beak, soft bird’s 

beak, and California sea-blite. Nesting habitat would be created for the California least tern. 

Further research on trail and noise disturbance effects to the CLRA would be conducted. Avian 

and mammalian predator management actions would be conducted to protect listed species. High 

marsh and ecotone would be enhanced or raised where possible to benefit tidal marsh listed 

species. CCG would be seeded into restored vernal pools, where warranted. Increased law 

enforcement, public education, and staff training would reduce wildlife disturbance and benefit 

listed species.

Other Species. Additional survey efforts, including completing baseline population density, 

presence/absence, and/or abundance surveys would be conducted on focal plant and animal 
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species. Additional surveys would be conducted on the California black rail, song sparrow 

subspecies, and salt marsh common yellowthroat. Survey and mapping of occupied burrowing owl 

nesting habitat and pairs would be conducted on the Refuge; Refuge staff would also participate in 

regional burrowing owl surveys. Coordinate with other burrowing owl survey partners (e.g., 

Santa Clara Valley Audubon Society, City of Mountain View Shoreline Park).Additional law 

enforcement, staff training, and public education would also benefit wildlife resource protection. 

Additional predator management focused on avian species (e.g., control of raptors that prey on 

threatened and endangered species) would also be conducted to benefit wildlife resources. 

Burrowing owl habitat would be sought for restoration as well.

Habitat Management. Under Alternative B, additional nesting habitat and habitat enhancements 

would be created for the western snowy plover and the California least tern. Additional tidal and 

managed marsh actions would be conducted at La Riviere Marsh, Mayhews Landing, and New 

Chicago Marsh where feasible. High marsh and ecotone would be heightened and expanded 

where possible to provide wildlife refugia. A comprehensive weed and re-vegetation management 

plan would be implemented to control priority weeds, and controlled areas would be replaced with 

a native plant pallet. Priority weeds would be controlled using a variety of mechanical, cultural, 

thermal, and chemical methods. Further detail on weed targets are described in the Weed 

Management Plan which is appended to the CCP. 

In the Warm Spring subunit, invasive plant cover would be reduced to less than 30 percent using a 

variety of control measures. Also, biomass of residual dry matter would be reduced by 1,000–

1,200 pounds per acre through grazing. In 2012, the Refuge will begin to manage the adjacent 

444- acre former Pacific Commons Preserve (currently managed by ProLogis as required by 

mitigation), as part of the Warm Springs subunit. As a result of the increased acreage, the cattle 

grazing program would be managed among ten refuge pastures. Cows would be kept in several 

small herds and would be rotated seasonally throughout the pastures according to target grazing 

rates. Cows would remain in at least three small herds throughout the year and would not be 

moved off-site. The prescribed burn season at Warm Springs would be expanded to include 

summer. Cover of native upland plants would be enhanced by controlling weeds, managing the 

grazing program, and seeding. 

The Refuge staff would also work with partners to increase shorebird and waterfowl nesting 

habitat where possible in the Alviso, Mowry, and Newark Ponds. The marsh-upland ecotone 

would be enhanced and restored to a native plant dominant community, particularly at FaberLaumeister, La Riviere Marsh, the EEC, Pond A6, and Pond A8. The Refuge would also 

implement the Mosquito Management Plan which is appended to the CCP. Expansion of the 

restoration education program would also support restoration of the ecotone/transition zone. 

Acquisition. The Refuge would take a more active approach, working with partners and willing 

sellers to acquire the remaining lands within the approved acquisition boundary that meet the 

Refuge purposes. Using the 1990 Final Environmental Assessment, Potential Additions to the 

San Francisco Bay National Wildlife Refuge, Alameda, San Mateo, and Santa Clara Counties, 

California as a reference, the Refuge staff would assess and prioritize remaining lands within the 

approved acquisition boundary for acquisition (from willing sellers). Lands would be prioritized 

based on endangered species and other trust species (e.g., migratory birds) needs, as well as lands 

that have feasible opportunities to address climate change impacts (e.g., uplands near tidal marsh) 

such as sea-level rise.
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Public Uses. Under Alternative B, a visitor services plan would be developed with a unified 

message of three main themes developed for public programs and outreach. Refuge staff will also 

assess trail use, particularly on Refuge/Bay Trails, and develop additional management and 

monitoring guidelines. Step-down planning for trail uses would also be considered. Wildlife 

observation opportunities would be expanded through trail enhancements, additional viewing 

areas, and non-motorized boat launch/destination sites (in concert with the San Francisco Bay 

Area Water Trail). A raised boardwalk would be installed at Faber-Laumeister for wildlife 

observation, photography, and fishing. Additional wildlife viewing areas would be constructed 

where feasible. A remote camera would be installed near closed or sensitive areas to promote 

compatible wildlife observation. Water-based (e.g., canoe, kayak) launches would be explored and, 

if feasible, implemented at Alviso Slough, Newark Slough, Bair Island, and/or Dumbarton Bridge. 

Signage would be installed to reduce boating impacts. At least one universally-accessible 

photography blind would be constructed. A wildlife photography permit system would be 

developed to allow photographers additional access opportunities. A bus stop at headquarters 

would be explored and, if feasible, implemented to promote use of public transit. 

Hunt acreage and protocols would remain unchanged from Alternative A. Coordination with 

hunters would be improved through additional outreach meetings, an interactive Web site, 

additional hunt material and information, and hunt data collection. A volunteer program would be 

enhanced for the upkeep of current hunt blinds.

Fishing would be expanded under this alternative. The fishing pier at Marshlands Road would be 

renovated, including improving the fish cleaning stations. A small fishing platform would be 

installed at the Coyote Creek Lagoon and Faber-Laumeister sites (as mentioned previously) while 

fishing access would be explored at Alviso Slough.

To facilitate visitation and interpretation, a LEED-certified visitor center complex would be 

constructed at headquarters. Visitor contact services would be improved at the EEC through 

additional staffing. Two new interpretive programs would be rotated into the existing interpretive 

offerings to increase the diversity of activities. In addition, ten special events and nine outreach 

events would be offered. Tours of the vernal pools would be increased to four annually during the 

flowering season. All interpretive materials such as interpretive panels and information sheets 

would be updated.

Environmental Education. The environmental education program would be updated and 

expanded in several ways, such as through the remodel of the Environmental Education Center 

(EEC), updating current educator training materials, Spanish translation of materials and 

curriculum, and adding additional programs at different sites. The EEC would be updated to 

LEED-certified silver or better per Service and federal government sustainability and 

greenhouse gas reduction policies. Interpretive materials and programs would be developed 

based on these LEED features and their benefits to refuge resources. 

Educator training materials and other environmental education resources would be improved or 

expanded for all existing environmental education programs. Programs and materials would be 

offered in Spanish. Additional Science Night programs would be offered at more schools. The 

Restoration Education Program would be expanded to six high schools and four colleges as well as 

non-school based audiences. Enrichment activities would be expanded throughout the year for 
B-17

Habitat Heroes who support the Summer Camp Program. Like Alternative A, programs would 

continue to promote watershed study and water conservation in the San Jose/Santa Clara 

watershed, targeted at fifth grade through college levels. Four discovery packs would be 

redesigned to support environmental education programs.

Other. The Refuge would improve outreach to present careers in conservation at events and 

programs. A nature exploration area would also be developed at headquarters to promote the 

Service’s Children in Nature Initiative. Three virtual geocache and earth cache sites would be 

developed to encourage compatible outdoor exploration.

The volunteer program would be expanded through increased volunteer and volunteer hour 

solicitation goals. Volunteer training would be improved and the Refuge would recruit volunteers 

from different segments of the Bay Area. Site specific stewardship projects would be developed 

at Warm Springs, Alviso’s managed ponds, Moffett Bay Trail, Ravenswood, Bair Island, FaberLaumeister, and others as determined.

We are concerned that by allowing the continued use of dog walking near tidal marsh, we are 

opening the door to future use on other Refuge trails and across the Refuge System. To this end, 

dog-walking would be modified to limit dogs to trails primarily in the upland areas only, in order 

to reduce disturbance to tidal marsh species, including the endangered CLRA. A total of 0.8 miles 

of trails open to dog walking would be closed, out of 2.1 miles (a reduction of 38 percent). Dog 

walking beyond the Tidelands Trail bridge crossings would be prohibited. Also, shifting the 

section of trail between the Tidelands Spur Trail and the Harrier Spur Trail slightly inland would

be considered in order to expand a buffer between the trail and the adjacent tidal marsh which is 

at the same elevation (see Figure 2). This area is to remain open to dog walking in order to

accommodate the loop feature of the trail. Law enforcement and staff/volunteer contact with 

visitors would be increased to ensure compliance. Additional signage would be placed to inform 

the public about these dog walking changes. A three to six month monitoring program would also 

be implemented to ensure compliance. If impacts to wildlife or their habitats are identified that 

cannot be effectively mitigated, dog walking may be prohibited entirely.
B-18

Figure 2. Alternative B - Reduced Access for Dog Walking
B-19

Alternative C: same as B; and substantial increase in wildlife management, habitat 

management, visitor services, and the environmental education program.

Under Alternative C, the Refuge would increase the frequency of baseline monitoring, investigate 

reintroduction of the listed species, survey for listed plant species, and encourage additional 

research to benefit listed species. Additional habitat management actions include additional tidal 

marsh improvements, more aggressive control of invasive weeds, revegetation of grassland areas, 

and more aggressive enhancement and restoration of the marsh-upland ecotone. All “Big 6”

public uses would be further improved, such as opening additional hunt acreage, installing 

additional interpretive signage, constructing an auto tour route, and enhancing the environmental 

education program offsite, beyond the field trip experience. Additional staff and funding would be 

needed to implement this alternative.

Listed Species. Under Alternative C, the Refuge would conduct SMHM surveys in all Refuge 

marshes. The Refuge would also investigate and, if feasible, implement the reintroduction of the 

SMHM and the CLRA in appropriate Refuge habitat. Further studies would be encouraged 

through partners on how pepperweed density and plot size affect the SMHM. The Refuge would 

also contract or partner with others to investigate CLRA populations, fledging success, survival 

and dispersal rates, and interspecies aggression. The Refuge would also contract or partner to 

research habitat restoration and climate change effects on listed species. 

Other Species. Under Alternative C, the frequency of baseline monitoring would increase. Every 

five years, population density, presence/absence, abundance, and/or cover on focal plant and 

animal species would be conducted. Baseline abundance assessments would be conducted on 

native and non-native predators. The addition of a boat launch would improve law enforcement 

access to protect wildlife resources. The Refuge would also work with others to investigate 

mudflat and shallow pond biofilm relationship to shorebird diets. In addition, the Refuge would 

partner to monitor priority contaminants in priority species and work with others to establish 

threshold levels of contaminants.

Habitat Management. Additional tidal marsh enhancement would be conducted at the FaberLaumeister and Munster subunits. A more aggressive approach would be taken on weed control, 

such as reducing cover of invasive pepperweed by 50 percent. At the Warm Springs subunit, the 

Refuge would work with a nursery to collect seed from the site and amplify for hydroseeding on 

weedy areas of the subunit. A hydro-geomorphic survey would be conducted on Warm Springs to 

improve circulation through berm removal. Additional enhancements and restoration would be 

made along the marsh-upland ecotone in the Ravenswood and Alviso pond systems as feasible. 

Public Uses. Under Alternative C, additional interpretive signage and overlooks would be 

installed on the Shoreline and Alviso Slough Trails. Interpretive programs such as vernal pool 

tours (three times per week during the vernal pool flowering season) would be increased. EEC 

visitor contact services and staffing would be increased on weekends and weekdays. The Refuge 

would develop a walking path or footbridge from the bus stop at headquarters. An auto tour route 

along Marshlands Road would be developed with safe pullouts to facilitate wildlife observation and 

photography. Four or more universally-accessible photography blinds would be constructed to 

facilitate wildlife photography. A youth photography day camp would also be offered. The 

feasibility of a bus stop would also be explored at the EEC. Kayaks/canoes and bicycles would be 
B-20

purchased to facilitate wildlife observation programs and a boat dock would be constructed. At 

least one stop would be developed to meet the San Francisco Bay Water Trail goals. 

An additional 340 acres of pond habitat at A6 would be open to waterfowl hunting. A universallyaccessible hunt blind would also be constructed and additional hunting-related courses would be 

offered, particularly for youth. A fishing day would be offered at an additional site on the Refuge 

(other than the fishing pier).

Environmental Education. Under Alternative C, green/LEED building and other related 

workshops, classes, and tours would be offered on climate change impacts and how to reduce one’s 

carbon footprint. The EEC would be used to conduct vocational education and college-level 

environmental education programs focused on reducing climate change impacts to wetlands (e.g., 

reducing carbon footprint, green/LEED building). 

The Wetland Round-up and Restoration Education Programs would be significantly expanded. 

Both programs and related materials would be enhanced and additional materials developed to 

enrich the field-based experience. The Refuge staff would work more closely with schools to 

enhance learning beyond the Refuge through its Schoolyard Habitats, Green Teams, School 

Waste Diversion, and other programs. The programs and their materials would be translated into 

additional languages beyond Spanish. The Refuge would also train existing and new partners to 

host the Wetland Roundup Program to new audiences. The Restoration Education Program 

would be expanded to additional sites such as Bair Island. Also, this program would be expanded 

beyond Alternative B to include ten high schools, eight colleges, vocational education programs, 

master gardener programs, eight non-school based audiences, and local community programs 

(e.g., waste reduction, community gardens). 

The Summer Camp Program would be expanded from 80 campers to 120. The Habitat Heroes 

Program, which supports the Summer Camp, would also be expanded to accommodate more 

young adults, and more enrichment opportunities would be provided. The Slow the Flow Program 

would be expanded to cover additional watersheds not served by the San Jose/Santa Clara Water 

Pollution Control Plan. Additional water quality programs would be expanded to colleges.

Other. The volunteer program would be the same as Alternative B. Dog walking would be 

prohibited on the entire Refuge. Other non-wildlife dependent recreational uses would be 

expanded, including offering six virtual geocache and six earth caches sites as well as a nature 

exploration area at the EEC.
B-21

Table 1. Summary of Alternatives 

Alternative A: No Action (Status Quo) Alternative B: moderate increase in 

wildlife management, habitat 

management, visitor services, and 

environmental education programs

Alternative C: substantial increase in 

wildlife management, habitat 

management, visitor services and 

environmental education

Biological

Monitoring and Research • Conduct annual surveys on migratory 

waterfowl and shorebirds.

• Support monthly surveys of shorebird 

and waterfowl use of salt ponds and 

managed ponds; assess water quality 

within those ponds.

• Support fish monitoring in sloughs and 

restored tidal marshes.

• Support monitoring and research on 

nesting success of shorebirds, terns, 

and gulls.

• Same as Alternative A.

• Same as Alternative A.

• Same as Alternative A.

• Same as Alternative A.

• Complete baseline population density, 

presence/absence, abundance, and/or 

cover on focal plant and animal species.

• Participate in regional database (e.g., 

CNDDB, E Bird, BIOS) to make data 

publicly available.

• Develop standardized quantitative and 

qualitative monitoring protocols.

• Conduct surveys of California black rail, 

song sparrow subspecies, and 

saltmarsh common yellowthroat.

• Assess the status of burrowing owls on 

the Warm Springs sub-unit. Maintain 

short grass/vegetation height prior to

nesting season to facilitate site 

selection.

• Conduct survey and mapping of 

occupied burrowing owl nesting habitat 

and pairs on the Refuge; participate in 

regional burrowing owl surveys. 

Coordinate with other burrowing owl 

survey partners (e.g., Santa Clara 

Valley Audubon Society, City of 

Mountain View Shoreline Park).

• Same as Alternative A.

• Same as Alternative A.

• Same as Alternative A.

• Same as Alternative A.

• Same as Alternative B.

• Same as Alternative B.

• Same as Alternative B.

• Same as Alternative B.

• Same as Alternative B.

• Same as Alternative B.

• Monitor population density, 

presence/absence, abundance, and/or 

cover on focal plant and animal species 
B-22

Alternative A: No Action (Status Quo) Alternative B: moderate increase in 

wildlife management, habitat 

management, visitor services, and 

environmental education programs

Alternative C: substantial increase in 

wildlife management, habitat 

management, visitor services and 

environmental education

every five years.

Listed Species • Conduct annual CLRA surveys (call 

counts and high tide surveys) within a 

subset of Refuge units.

• Support monitoring and research on 

nesting success of western snowy 

plovers.

• Conduct opportunistic surveys for 

SMHM in select marshes.

• Same as Alternative A.

• Same as Alternative A.

• Conduct SMHM surveys annually within 

a subset of existing, restored, and 

managed marshes.

• Revise and implement monitoring plan 

for listed and native species.

• Increase western snowy plover 

productivity through nest site 

enhancement, management actions, 

and associated monitoring.

• Create suitable nesting habitat for at 

least one colony of California least tern.

• Investigate CLRA response to 

disturbance, including sensitivity to 

noise and trail use. 

• Survey/monitor for Suisun thistle, salt 

marsh bird’s beak, soft bird’s beak, and 

California sea-blite distribution and 

abundance.

• Same as Alternative A.

• Same as Alternative A.

• Conduct SMHM surveys annually in all 

marshes.

• Same as Alternative B.

• Same as Alternative B.

• Same as Alternative B.

• Same as Alternative B.

• Same as Alternative B.

• Investigate reintroduction of SMHM and 

CLRA into potential habitat that does not 

currently contain these species.

• Support studies to ascertain at what 

density and plot size of pepperweed salt 

marsh harvest mice are excluded.

• Contract or partner with others to 

investigate limits to CLRA populations, 

such as fledging success, survival and 

dispersal rates, and interspecies 

aggression. 

• Contract or identify partners to research 

habitat restoration and climate change 
B-23

Alternative A: No Action (Status Quo) Alternative B: moderate increase in 

wildlife management, habitat 

management, visitor services, and 

environmental education programs

Alternative C: substantial increase in 

wildlife management, habitat 

management, visitor services and 

environmental education

effects on listed species.

Tidal and Managed Marsh 

Management

• Conduct restoration projects (e.g., Bair 

Island, SBSPRP).

• Support research and monitoring to 

determine vegetation and sedimentation 

rates of newly restored areas. 

• Same as Alternative A.

• Same as Alternative A.

• Heighten and expand high marsh and 

ecotone/transition zone wherever 

possible on the Refuge.

• Improve ecological function (e.g., 

hydrology, habitat management) at La 

Riviere Marsh, Mayhews Landing, and 

New Chicago Marsh units.

• Same as Alternative A.

• Same as Alternative A.

• Same as Alternative B.

• Same as Alternative B, and also 

improve ecological function at FaberLaumeister and Munster subunits to 

enhance tidal marsh habitat.

Predator Management • Conduct predator management through 

USDA Wildlife Services based on 

existing predator management plan.

• Implement an updated mammalian 

predator management plan, and 

implement avian predator management.

• Assess efficacy of predator 

management program on increasing 

numbers of listed species and breeding 

birds.

• Develop outreach message to visitors 

and neighbors.

• Same as Alternative B.

• Same as Alternative B.

• Same as Alternative B.

• Assess baseline abundance of native 

and non-native predators.

Wildlife Disturbance • Conduct law enforcement patrols. • Increase law enforcement patrols.

• Develop and conduct training and other 

tools for staff, partners, special use 

permit holders, volunteers, neighbors, 

and visitors to reduce trespass and 

disturbance.

• Conduct public outreach program to 

promote responsible, water-based 

recreation.

• Same as Alternative B.

• Same as Alternative B.

• Same as Alternative B.

• Develop a boat launch site for improved 

law enforcement access.

Weed and Vegetation 

Management

• Work with partners to conduct chemical 

control of invasive Spartina. 

• Conduct intermittent control of invasive 

pepperweed and other priority weeds 

through chemical and manual methods.

• Same as Alternative A.

• Complete and implement a weed 

management and re-vegetation plan.

• Same as Alternative A.

• Same as Alternative B.
B-24

Alternative A: No Action (Status Quo) Alternative B: moderate increase in 

wildlife management, habitat 

management, visitor services, and 

environmental education programs

Alternative C: substantial increase in 

wildlife management, habitat 

management, visitor services and 

environmental education

• Control weeds, for example, contain 

invasive perennial pepperweed at 

boundaries and reduce cover of the 

main infestations on the Refuge by 20

percent as derived from the 2010–2011 

baseline inventory within threatened and 

endangered species habitat (high tide 

refugia, transition zone, and tidal areas).

• Further control of weeds; for example,

reduce cover of invasive perennial 

pepperweed on the Refuge by 50

percent of 2010–2011 baseline 

inventory within threatened and 

endangered species habitat (high tide 

refugia, transition zone and tidal areas).

• Coordinate with others to conduct 

region-wide weed control efforts.

• Increase acreages for weed control.

Vernal Pool and Grassland 

Management

• Conduct vernal pool surveys.

• Use grazing and prescribed burning 

(Sept. 1-Oct. 15) to reduce biomass of 

residual dry matter.

• Same as Alternative A.

• Reduce invasive plant cover to less than 

30 percent using mechanical, manual, 

and chemical control treatments.

• Reduce biomass of residual dry matter 

to 1000–1200 lbs. per acre using 

grazing.

• Expand prescribed burn season to 

include summer (Jun. 15-Oct. 15).

• Increase cover of native upland plants 

by 10 percent by weed control, grazing, 

and seeding.

• Same as Alternative A.

• Same as Alternative B.

• Same as Alternative B.

• Same as Alternative B. 

• Same as Alternative B.

• Contract with a nursery to collect seed 

on site and amplify. Hydroseed weedy 

areas and cover with rice straw.

• Conduct hydro-geomorphic survey and 

improve circulation through berm 

removal.

Managed Pond and 

Mudflat Management

• Restoration and enhancement through 

SBSPRP.

• Create islands throughout managed 

ponds as possible during levee 

maintenance work.

• Manage ponds at different water levels 

for a variety of bird species.

• Same as Alternative A.

• Same as Alternative A.

• Same as Alternative A.

• Work with partners to explore increasing 

nesting and roosting habitat to benefit 

shorebirds and waterfowl in the Alviso, 

Ravenswood, Mowry, and Newark 

• Same as Alternative A.

• Same as Alternative A.

• Same as Alternative A.

• Same as Alternative B.
B-25

Alternative A: No Action (Status Quo) Alternative B: moderate increase in 

wildlife management, habitat 

management, visitor services, and 

environmental education programs

Alternative C: substantial increase in 

wildlife management, habitat 

management, visitor services and 

environmental education

Ponds.

• Investigate the importance of mudflat 

and shallow pond biofilm on shorebird 

diet and the potential for management 

for biofilm.

Ecotone/Transition Zone • Sporadic weed removal by chemical and 

manual means.

• Sporadic planting done in ecotone and 

transition zones by staff and volunteers.

• Work with local city government to 

control nesting Canada geese in newly 

restored upland and ecotone habitats.

• Weed control conducted through weed 

management and re-vegetation plan.

• Utilize staff and volunteers to plant in 

ecotone and transition zones according 

to re-vegetation plan priorities.

• Same as Alternative A.

• Enhance and restore marsh-upland 

ecotone, especially at FaberLaumeister, La Riviere Marsh, EEC, 

Pond A6, and Pond A8 through 

established a dominance (>50%) of 

native plants.

• Conduct restoration education program 

focusing on ecotone/transition zone 

(e.g., Warm Springs, Alviso, Fremont, 

and East Palo Alto).

• Identify potential acquisition areas to 

provide burrowing owl habitat.

• Implement a plan to restore the ecotone 

of Faber-Laumeister and implement 

monthly plant maintenance.

• Same as Alternative B.

• Same as Alternative B.

• Same as Alternative A.

• Enhance and restore marsh-upland 

ecotone along all levees in the 

Ravenswood and Alviso pond systems 

through established dominance (>50%) 

of native plants.

• Same as Alternative B.

• Same as Alternative B.

• Same as Alternative B.

Acquisition • Acquire lands within the approved 

acquisition boundary that meet the 

Refuge purposes from willing sellers 

when refuge resources allow

• Refuge would actively approach willing 

sellers to acquire the remaining lands 

within the approved acquisition 

boundary. Refuge would assess and 

prioritize remaining lands within the 

approved acquisition boundary.

• Same as Alternative B.

Partnerships • Continue existing partnerships to 

support the biology, visitor services, and 

management needs of the Refuge.

• Work with Friends group to promote 

public awareness and outreach of the 

Refuge.

• Maintain, enhance, and develop at least 

10 new projects or partners to preserve, 

restore, and enhance the Refuge.

• Same as Alternative A.

• Maintain enhance, and develop at least 

20 new projects or partners to preserve, 

restore, and enhance the Refuge.

• Same as Alternative A.
B-26

Alternative A: No Action (Status Quo) Alternative B: moderate increase in 

wildlife management, habitat 

management, visitor services, and 

environmental education programs

Alternative C: substantial increase in 

wildlife management, habitat 

management, visitor services and 

environmental education

Disease • Respond to botulism outbreaks in 

wetland and pond habitats.

• Work with partners (e.g., SBSPRP and 

Regional Water Quality Control Board) 

to monitor priority species for mercury 

contamination. 

• Work with local mosquito abatement 

districts to manage threat of mosquitoborne disease on the Refuge through 

physical, biological, and chemical 

methods.

• Same as Alternative A.

• Same as Alternative A.

• Implement a mosquito management 

plan. 

• Monitor and mitigate effects of disease 

outbreaks that affect wildlife, plants, and 

public health.

• Same as Alternative A.

• Work with partners (e.g., SBSPRP and 

RWQCB) to monitor priority species for 

priority contaminants in addition to 

mercury (PCBs, etc.).

• Same as Alternative B. 

• Same as Alternative B.

• Work with partners to establish 

threshold levels of contaminants (e.g., 

Hg) in priority species. 

Climate Change • Partner with others to share and 

improve knowledge about climate 

change science.

• Encourage and seek funding for climate 

change modeling.

• Coordinate with local partnerships (e.g., 

Bay Area Ecosystems Climate Change 

Consortium).

• Same as Alternative A.

• Same as Alternative A.

• Investigate and prioritize for acquisition, 

lands within the approved acquisition 

boundary in light of climate change 

impacts.

• Reduce carbon footprint of Refuge 

operations by 30 percent using 

renewable energy sources and reducing 

facility, vehicle, and workforce costs.

• Coordinate with the Service’s 

Landscape Conservation Cooperatives

and Inventory and Monitoring (I&M) 

efforts to address near-term and longterm climate change impacts. Identify 

and coordinate with new local climate 

change partnerships.

• Investigate and prioritize for acquisition, 

lands within the approved acquisition 

boundary that have feasible 

• Same as Alternative A.

• Same as Alternative A.

• Same as Alternative B.

• Same as Alternative B.

• Same as Alternative B.

• Same as Alternative B.
B-27

Alternative A: No Action (Status Quo) Alternative B: moderate increase in 

wildlife management, habitat 

management, visitor services, and 

environmental education programs

Alternative C: substantial increase in 

wildlife management, habitat 

management, visitor services and 

environmental education

opportunities to address sea-level rise 

impacts for marsh migration and other 

effects from climate change.

• Identify and implement best practices to 

mitigate climate change impacts.

• Same as Alternative B.

Land Management 

Priorities

• Acquire remaining lands within the 

approved acquisition boundary of the 

Refuge as approached by willing sellers.

• Actively work with partners and willing 

sellers to acquire remaining lands within 

the approved acquisition boundary of 

the Refuge.

• Same as Alternative B.

Public Uses

• Visitor Services division offers a variety 

of programs related to Refuge 

Resources.

• Develop and implement a unified 

message with three main themes for the 

public. Incorporate the unified message 

in all programs and outreach.

• Develop a visitor services plan.

• Same as Alternative B.

• Same as Alternative B.

Wildlife Observation • Provide more than 30 miles trail, 

multiple access sites, and overlooks to 

facilitate wildlife observation.

• Offer guided walks.

• Enhance, maintain, and expand public 

access opportunities (e.g., improve 

Tidelands Trail by installing water bars 

to slow erosion).

• Same as Alternative A.

• Assess trail use, particularly on 

Refuge/Bay Trails, and develop 

additional management and monitoring 

guidelines. Consider step-down 

planning for trail uses.

• Install a raised boardwalk extending the 

entire length of the interior levee of the 

Faber-Laumeister site.

• Explore the feasibility of a bus stop at 

the Fremont headquarters entrance.

• Investigate and if feasible construct 

additional wildlife viewing facilities.

• Install a remote camera near closed 

• Same as Alternative B.

• Same as Alternative A.

• Same as Alternative B.

• Install interpretive signage and 

overlooks on the Shoreline and Alviso 

Slough Trails.

• Same as Alternative B.

• Same as Alternative B.

• Explore the feasibility of a bus stop at 

the EEC.

• Develop a walking path/bridge from the 

bus stop to headquarters.

• Same as Alternative B

• Same as Alternative B.
B-28

Alternative A: No Action (Status Quo) Alternative B: moderate increase in 

wildlife management, habitat 

management, visitor services, and 

environmental education programs

Alternative C: substantial increase in 

wildlife management, habitat 

management, visitor services and 

environmental education

and/or sensitive areas for the purpose of 

remote public viewing.

• Research and if feasible promote waterbased wildlife observation at Alviso 

Slough, Newark Slough, and Bair Island 

(canoe, kayak tours).

• Identify potential canoe and kayak 

launch/destination sites on the Refuge 

(e.g., near Dumbarton Bridge/fishing 

pier).

• Same as Alternative B.

• Buy kayaks or canoes for water-based, 

wildlife observation programs.

• Construct a dock on the Refuge.

• Develop at least one stop on the 

proposed Water Trail.

Photography • Provide more than 30 miles of trail, 

multiple access sites, and overlooks to 

facilitate wildlife observation.

• Offer guided photography walks.

• Same as Alternative A.

• Same as Alternative A.

• Construct and maintain at least one 

universally-accessible photography 

blind.

• Implement a wildlife photography permit 

system.

• Same as Alternative A.

• Same as Alternative A.

• Construct and maintain four or more 

universally-accessible photography 

blinds.

• Same as Alternative B.

• Offer a week-long photography day

camp for youths 13–16.

Hunting • Permit seasonal waterfowl hunting on 

7,500 acres of ponds, tidal areas, and 

open Bay.

• Conduct a hunter orientation meeting.

• Enact an annual waterfowl hunt fee that 

would provide continued funding to 

improve hunt blinds, hunt access, and 

• Same as Alternative A.

• Increase number of meetings to solicit 

hunter feedback.

• Track hunt use over a five-year period 

once major tidal restoration breaches 

are completed to determine use.

• Develop an interactive hunt Web site for 

hunt permits, interactive hunt maps, 

relevant links to other hunt information, 

and collection of hunt data.

• Same as Alternative A.

• Open an additional 340 acres to hunting 

(Pond A6).

• Same as Alternative B.

• Same as Alternative B.

• Same as Alternative B.

• Same as Alternative A.
B-29

Alternative A: No Action (Status Quo) Alternative B: moderate increase in 

wildlife management, habitat 

management, visitor services, and 

environmental education programs

Alternative C: substantial increase in 

wildlife management, habitat 

management, visitor services and 

environmental education

outreach and education materials.

• Develop brochures and wayside exhibits 

for hunting.

• Same as Alternative B.

• Construct an additional universallyaccessible hunt blind.

• Offer bird identification, hunter safety, 

and youth hunt education classes.

Fishing • Permit year-round pier fishing at 

headquarters.

• Permit shoreline fishing at Coyote Creek 

Lagoon and Faber-Laumeister.

• Host annual fishing day at pier.

• Same as Alternative A, also update 

fishing pier including renovation of fish 

cleaning stations.

• Improve fishing facilities at Coyote 

Creek Lagoon and Faber-Laumeister 

with a small fishing platform.

• Same as Alternative A.

• Develop brochures and wayside exhibits 

for fishing.

• Assess and, if possible, provide 

shoreline fishing to Alviso Slough.

• Same as Alternative B

• Same as Alternative B.

• Conduct one additional fishing day at 

another fishing access site.

• Same as Alternative B.

• Same as Alternative B.

Interpretation and 

Outreach

• Maintain a Visitor Contact Station in 

Fremont.

• Provide limited visitor contact services 

at the EEC.

• Offer about 200 guided interpretive 

activities (walks and other programs) on 

a variety of topics at different sites on 

the Refuge.

• Offer self-guided interpretive exhibits 

and materials at the visitor center and 

EEC, some in Spanish.

• Offer Discovery Pack Program, a selfguided interpretive walk targeted at 

families.

• Host seven special on-site events, such 

as Earth Day Cleanup, Endangered 

• Construct a visitor center complex (e.g., 

auditorium, resource library, staff 

offices, and EE facilities) in Fremont to 

Silver LEED certification or better.

• Update the Environmental Education 

Center building and grounds to Silver 

LEED certification or better. Update 

EEC to improve visitor contact services 

on weekends.

• Increase the diversity of interpretation 

activities by offering two new interpretive 

programs annually.

• Same as Alternative A.

• Same as Alternative A.

• Host a minimum of 10 Special Events 

on site each year.

• Same as Alternative B.

• Improve EEC visitor contact services on 

weekends and weekdays.

• Same as Alternative B.

• Same as Alternative A.

• Same as Alternative A.

• Host a minimum of 12 Special Events 

on site each year.
B-30

Alternative A: No Action (Status Quo) Alternative B: moderate increase in 

wildlife management, habitat 

management, visitor services, and 

environmental education programs

Alternative C: substantial increase in 

wildlife management, habitat 

management, visitor services and 

environmental education

Species Poster Contest, South Bay Bird 

Fest, and National Wildlife Refuge 

Week.

• Publish quarterly Tideline newsletter, 

Sloughs News, and other written 

outreach materials.

• Manage Website and Facebook 

postings.

• Offer podcast tours of the EEC and 

headquarters.

• Participate in six outreach events each 

year such as fairs and festivals.

• Planting and weeding activities with 

special groups.

• Partnerships with youth-oriented 

programs.

• Offer 1–2 tours on vernal pool 

management at Warm Springs during 

the flowering season.

• Same as Alternative A.

• Same as Alternative A.

• Develop two new audio tours.

• Conduct a minimum of nine outreach 

events each year.

• Same as Alternative A.

• Same as Alternative A.

• Increase interpretation at Warm Springs, 

including increasing to four tours during 

the vernal pool flowering season.

• Update old or outdated interpretive 

materials such as information sheets 

and interpretive panels.

• Develop outreach materials to promote 

wildlife disturbance reduction messages 

within the water-based recreation user 

group.

• Same as Alternative A.

• Same as Alternative A.

• Same as Alternative B.

• Develop a Refuge Podcast.

• Conduct a minimum of 15 outreach 

events each year.

• Same as Alternative A.

• Same as Alternative A.

• Increase vernal pool tours to three times 

per week during the peak vernal pool 

flowering season.

• Same as Alternative B.

• Provide equipment for interpretive 

programs, including bicycling and

kayaking.

• Seek out partners to conduct 

interpretive programs.

• Create an auto tour route along 

Marshlands Road by offering safe 

pullouts for vehicles to observe and 

photograph wildlife.

• Same as Alternative B.

• Preserve and interpret salt pond history 

such as hunting and infrastructure.

Environmental Education • EEC Building built in 1979. • Update the Environmental Education 

Center building and grounds to Silver 

• Same as Alternative B.
B-31

Alternative A: No Action (Status Quo) Alternative B: moderate increase in 

wildlife management, habitat 

management, visitor services, and 

environmental education programs

Alternative C: substantial increase in 

wildlife management, habitat 

management, visitor services and 

environmental education

LEED certification or better.

• Develop interpretive materials & 

programs to present green/LEED 

features as conservation measures that 

can be replicated.

• Use green elements as teaching tools in 

environmental education and climate 

change curriculum.

• Offer green/ LEED building and 

reducing carbon footprint workshops, 

classes, and tours.

• Same as Alternative B.

• Use the EEC for vocational education 

programs and college level 

environmental education programs 

focusing on climate change impacts to 

wetlands (e.g., reducing carbon 

footprint, and green/ LEED building). 

Wetland Round-up 

Program

• Offer 3–4 field trips per week at two

sites.

• Improve educator training and pilot new 

environmental education resources for 

use by educators and partners.

• Revise Salt Marsh Manual.

• Translate Salt Marsh Manual into 

Spanish.

• Offer programs in Spanish.

• Develop new teacher and student 

resources.

• Develop and enhance training materials 

for educator lead field trips, (including

electronic materials, DVDs, and Webbased materials).

• Same as Alternative B.

• Same as Alternative B.

• Translate Salt Marsh Manual into 

Spanish and other languages (based on 

needs assessment).

• Offer programs, continued education, 

and training in foreign language and 

translation.

• Develop new teacher and student 

resources and new supporting activities 

to enrich field trips (such as Web-based 

pre- and post- visit activities and 

classroom based laboratory studies; 

provide equipment for these activities).

• Develop and enhance training materials 

for educator lead field trips, (including

electronic materials, DVDs, and Webbased materials), and work with schools 

to extend the field trip experience and 

enhance learning by providing training 

and support for Schoolyard Habitats, 
B-32

Alternative A: No Action (Status Quo) Alternative B: moderate increase in 

wildlife management, habitat 

management, visitor services, and 

environmental education programs

Alternative C: substantial increase in 

wildlife management, habitat 

management, visitor services and 

environmental education

• Train partners to host Wetland Roundup Field Trip programs for other groups 

(e.g., Girl Scouts, Marine Science 

Institute).

Green Teams, School Waste Diversion 

Programs, and other such activities.

• Train existing partners to host Wetland 

Round-up Field Trip programs for other 

groups; obtain new partnerships and 

grants for teacher institutes that would

train partners and reach new audiences.

Science Night • Science Night for George Mayne School 

annually at the Environmental Education 

Center.

• Continue to host Science Night for 

George Mayne School and expand to 

host and attend Science Night programs 

for other schools.

• Same as Alternative B.

Restoration Education 

Program

• Pilot field trip program in Alviso, Logan 

HS, and Habitat Heroes programs at 

Fremont; Youth Conservation Corps 

program in East Palo Alto.

• Develop & expand environmental 

education programs focused on habitat 

restoration for neighboring communities.

• Develop environmental education 

programs focused on habitat restoration 

in Warm Springs, Alviso, Fremont, and 

East Palo Alto.

• Research and implement restoration 

education at Mayhew’s Landing and a 

Science Night with neighboring schools.

• Expand restoration education audience 

to include six high schools and four 

colleges.

• Translate restoration education 

materials into Spanish.

• Offer programs in Spanish.

• Expand restoration education program 

to include four non-school based 

• Same as Alternative B.

• Same as B, but add additional sites 

such as Bair Island.

• Same as B, but also develop supporting 

activities and materials to extend the 

field experience (using programs such 

as Schoolyard Habitats and Green 

Teams).

• Expand restoration education audience 

to include ten high schools and eight 

colleges.

• Work with vocational education 

programs and master gardeners to 

promote native plant gardens in local 

communities.

• Offer programs and translate restoration 

education materials into Spanish and 

other languages (based on needs 

assessment).

• Provide continued education and 

training in foreign language and 

translation.

• Expand restoration education audiences 

to include eight non-school based 
B-33

Alternative A: No Action (Status Quo) Alternative B: moderate increase in 

wildlife management, habitat 

management, visitor services, and 

environmental education programs

Alternative C: substantial increase in 

wildlife management, habitat 

management, visitor services and 

environmental education

audiences. audiences and extend restoration 

education to include community 

programs such as waste reduction and 

community gardens.

Summer Camp Programs • Two camps each summer serving 80 

campers (Marsh-In Camp for grades 1–

6, Habitat Heroes for grades 7–12).

• Same as Alternative A.

• Offer enrichment activities throughout 

the year for Habitat Heroes.

• Offer two weeks of Marsh-In Camp to 

accommodate 120 campers.

• Accommodate more teens by offering a

program for new Habitat Heroes and 

refresher program for returning Habitat 

Heroes.

• Offer a greater enrichment trip for 

Habitat Heroes as well as the activities 

throughout the year.

Slow the Flow Integrated 

Field Trip Program

• Seven cities served (San Jose, Santa 

Clara, Cupertino, Milpitas, Los Gatos, 

Monte Sereno, and Campbell) with Slow 

the Flow Integrated Field Trip Program.

• Offer programs for upper grade classes 

(fifth grade through college).

• Continue to offer programs that promote 

watershed study and water conservation 

in the area served by the San Jose 

Santa Clara Water Pollution Control 

Plant.

• Continue to offer programs for upper 

classes (fifth grade through college).

• Increase capacity for joint Water 

Pollution Control Plant/Environmental 

Education Center tour programs (more 

tours and improved curriculum).

• Expand to include other watersheds on 

the Refuge not served by the San Jose 

Santa Clara Water Pollution Control 

Plant.

• Same as Alternative B.

• Same as Alternative B.

• Install digital water quality monitoring 

station in Artesian Slough for field trip 

use.

• Develop more specialized curriculum 

and supporting materials for colleges.

Offsite Environmental 

Education

• Host a booth at Bay Area Environmental 

Education Resource Fair.

• Participate in Audubon Wildlife 

Education Day.

• Same as Alternative A.

• Same as Alternative A.

• Develop and present careers in 

conservation program for outreach 

events and programs.

• Develop and lead workshops at BAEER 

fair.

• Attend additional local offsite events that 

support the goals of the environmental 

education program.

• Continue outreach and more career 

development and training (through 

internships, Student Temporary 

Employment Program positions, Youth 

Conservation Corps, and other 
B-34

Alternative A: No Action (Status Quo) Alternative B: moderate increase in 

wildlife management, habitat 

management, visitor services, and 

environmental education programs

Alternative C: substantial increase in 

wildlife management, habitat 

management, visitor services and 

environmental education

• Conduct Slow the Flow Outreach or 

other environmental education events.

• Same as Alternative A.

programs).

• Continue outreach and teach at 

Resource Area For Teaching

Workshops.

Scout Programs • Scout programs (badge program and 

service projects) offered by Santa Clara 

Valley Urban Runoff Pollution 

Prevention Program in Alviso and 

offered by volunteers in Fremont.

• Support Scout programs with materials 

(Discovery Packs).

• Same as Alternative A.

• Redesign four Discovery Packs with 

self-guided activities.

• Expand badge offerings.

• Offer Scout camps.

• Offer programs in conjunction with the 

national Scout offices.

• Create eight Scout packs.

• Offer Train-the-Trainer workshops to 

Scout Leaders for use of the packs.

Special Environmental 

Education Events 

(Provided by Slow the 

Flow/Santa Clara Valley 

Urban Runoff Pollution 

Program grants)

• Continue to offer two annual outreach 

events at the EEC (South Bay Bird 

Festival, and Spooky Slough/Shark 

Day).

• Same as Alternative A.

• Collaborate with and incorporate 

additional partner organizations that 

would contribute to outreach activities 

and the Refuge mission.

• Same as Alternative A.

• Increase event capacity (facilitate 

additional transportation and staff, 

volunteer, and visitor parking).

• Increase FWS staff participation when 

possible (site preparation, on-site 

assistance).

Other Recreational Uses • Dog walking would continue on 

designated trails at the headquarters.

• Permit bicycling.

• Offer one virtual geocache site.

• Permit boating on the Bay and 

tributaries of the Refuge.

• Limit dog walking only to the upland

portion of trails near the headquarters.

• Same as Alternative A.

• Offer three virtual geocache sites and 

three earth cache sites.

• Same as Alternative A.

• Develop a nature exploration area at 

headquarters to promote Children in 

Nature Initiative.

• Prohibit dog walking on the entire 

Refuge.

• Same as Alternative A.

• Offer six virtual geocache sites and six

earth cache sites.

• Construct a boat dock.

• In addition to headquarters, develop a 

nature exploration area at EEC.

Volunteers • Manage internship and volunteer 

programs to support biology, 

environmental education, visitor 

• Expand volunteer program though 

increasing volunteers and volunteer 

hours.

• Same as Alternative B.
B-35

Alternative A: No Action (Status Quo) Alternative B: moderate increase in 

wildlife management, habitat 

management, visitor services, and 

environmental education programs

Alternative C: substantial increase in 

wildlife management, habitat 

management, visitor services and 

environmental education

services, and management needs.

• Recruit volunteers from businesses, 

community groups, and court-ordered 

community service to conduct long-term 

projects such as weed removal, 

cleanups, and plantings.

• Same as Alternative A.

• Expand volunteer docent program and 

materials (volunteer development, 

training, evaluation, and recruitment).

• Develop permanent stewardship 

projects for: Warm Springs, Alviso 

managed ponds, Moffett Bay Trail, 

Ravenswood, Bair Island, FaberLaumeister, and others.

• Develop one volunteer program every 

five years that outreaches to different 

segments of the bay-area community. 

• Separate visitor center roles from 

volunteer coordinator roles.

• Same as Alternative A.

• Same as Alternative B.

• Same as Alternative B.

• Same as Alternative B.

• Same as Alternative B.
B-36

Figure 3. Visitor Service and Environmental Education Activities for Alternative A
B-37

Figure 4. Visitor Service and Environmental Education Activities for Alternative B
B-38

Figure 5. Visitor Service and Environmental Education Activities for Alternative C
B-39

Chapter 3. Affected Environment

This chapter is intended to describe the physical, biological, and cultural resources, as well as the

social and economic environment that would most likely be affected by the alternatives. Chapter 

3, Affected Environment, of the CCP provides a detailed description of each of these components.
B-40

Chapter 4. Environmental Consequences

Chapter 4 analyzes the environmental impacts expected to result from implementation of the 

alternatives. Potential impacts to these resources are characterized by evaluating direct, indirect, 

and cumulative impacts for each alternative where applicable. Direct impacts are generally 

caused by the proposed actions and occur at the same time and place as the action, such as 

flushing of wildlife from wildlife observation activities. Indirect impacts are defined as reasonably 

foreseeable effects caused by the proposed action, but occurring later in time or farther away from 

the source of impact than direct effects. An example of an indirect impact is habitat modification 

that results in a change in abundance, breeding success, or prey availability. Cumulative effects 

would occur when incremental direct or indirect impacts are added to the impacts of other past, 

present and reasonably foreseeable future actions, regardless of the agency or person who 

undertakes them. The analysis is organized by each aspect of the environments described in 

Chapter 3 of the CCP, including physical, biological, cultural, social, and economic resources. The 

purpose of the analysis is to provide the context and intensity of the impacts of the action such 

that a determination of significance can be made by the decision-makers.

The analysis of environmental consequences focuses on all units of the Refuge. A separate, 

detailed NEPA analysis has been completed for individual restoration projects, such as the Bair 

Island Restoration Project and the SBSPRP. The discussion and analysis in these documents is 

incorporated by reference, but the following analysis is focused on new actions proposed under the 

CCP. 

NEPA requires the development of mitigation measures when Federal activities are likely to 

result in adverse impacts on the human environment. The EA and CCP identify measures that 

would avoid and minimize any environmental impacts that could occur during implementation of 

the CCP. Alternative A (no action) is a continuation of management practices that are currently 

in place and serves as a baseline against which Alternatives B and C are compared.

Physical Resources

Hydrology

Common to All Alternatives

Because much of the Refuge is located at or below sea level, much of the Refuge is affected by tide 

changes in the Estuary. Levees and water control features from prior development have altered 

the hydrological patterns (i.e., natural slough channels) in the area resulting in poor water 

circulation, such as trapping of stagnant water in some areas. Poor circulation has in turn 

resulted in poor quality tidal marsh vegetation. Under each of the alternatives, the restoration 

projects described in the Bair Island EIS/Environmental Impact Report (EIR) and the SBSPRP

EIS/EIR would continue to be implemented. Implementing these restoration projects means that 

some dry areas would be flooded long-term while other formerly diked ponds would begin to 

accumulate sediment from resumed tidal influence. Breaches and dredging associated with the 

restoration projects will cause high velocity water flows thereby inundating sites and scouring 

existing channels. Sediment (e.g., silt, clay, sand, and gravel) carried into low elevation areas will 

settle and discourage stagnating water. Over time, sedimentation will reduce these flows, improve 

floodplain function, encourage plant communities to form and stabilize the area, and channels will 

reach equilibrium. These hydrologic effects are discussed in detail in the EIS/EIR associated 
B-41

with the Bair Island restoration project and SBSPRP. The EIS/EIR for the SBSPRP provides 

both a programmatic analysis of hydrological impacts as well as a site specific analysis of the 

hydrologic impacts from implementing Phase 1 of the overall restoration project. As subsequent 

phases of the SBSPRP are developed, additional site specific analysis, including a NEPA 

document, will be completed. The NEPA documents for both the Bair Island project and the 

SBSPRP can be found at: www.southbayrestoration.org/index.html. 

From a public health perspective, stagnant waters breed mosquito populations that may carry 

diseases that are a threat to human health. Restoration activities associated with the Bair Island 

and SBSPRP are also expected to improve or restore hydrological patterns and wetland function, 

reduce stagnant waters, improve floodplain function, and result in an increase in tidal marsh 

habitat. These hydrological improvements should reduce mosquito populations, providing a 

benefit to public health as well as to wildlife communities. Mosquito management activities (i.e., 

mosquito population monitoring, disease surveillance, and habitat improvements) are not expected 

to negatively impact hydrology. Physical improvements such as ditching conducted by the 

mosquito abatement districts are expected to improve hydrology in areas with stagnant water 

issues. 

Routine operation and maintenance of the ponds is limited to maintaining the levees between the 

ponds and would not have any adverse impacts on the hydrology of ponds. Weed management 

activities, particularly manual removal of weeds by hand pulling, cutting, digging, chopping, 

uprooting (weed wrenching), sawing, weed-whacking, and mowing may expose soil and make it 

vulnerable to erosion. However, those sites will be replaced by native plants through 

hydroseeding or planting seedlings to prevent long-term soil loss.

The Service recognizes the need to protect levees and other structures for the purpose of public 

safety and protection of private property. As restoration projects are developed in the future, we 

will carefully evaluate hydrological impacts to neighboring public and private property before 

implementation. 

Alternative A

Under Alternative A, the restoration projects associated with Bair Island and the SBSP would 

continue to move forward, and the effects on hydrology would be the same as described under 

Common to All Alternatives.

Alternative B

Under Alternative B, additional hydrological improvements would be assessed and conducted as 

funding permits at La Riviere Marsh, Mayhews Landing, New Chicago Marsh, and others as 

possible. These sites are diked or sedimented, weedy, and have poor hydrological connectivity. 

Impacts similar to those described under Common to All Alternatives would occur. Earth moving 

on these sites may result in short-term changes (e.g., erosion, sedimentation) to their hydrology 

but with long-term benefits to improving floodplain function. As in Alternative A, ongoing 

restorations and enhancements have the potential to cause high velocity water flows thereby 

inundating sites and scouring channels. These water flows will reduce over time with the buildup 

of sedimentation and vegetation, and equilibrium being reached in channels. Additional analysis

for tidal impoundments and other hydrological issues would be assessed in site specific planning 

and NEPA document. Under Alternative B, construction of new nesting and roosting habitat for 

migratory birds will result in changes to the water flow in managed ponds, but is not likely to 
B-42

adversely affect the overall hydrology of the ponds.

Under this alternative, increased weed control activities as implemented by the weed management 

plan may result in more soil erosion than existing weed management. However, these sites will be 

replaced with native vegetation to prevent long-term soil erosion.

Alternative C

In addition to those elements in Alternative B, hydrological patterns would be assessed and 

improved at Faber-Laumeister, Munster, and Warm Springs. These improvements would result 

in similar impacts as described in Alternative B. Increased weed management activities would 

result in the same effects as described in Alternative B. 

Water Quality and Contaminants

Common to All Alternatives

Ongoing restoration actions described in the Bair Island and SBSP projects may cause short term 

water quality impacts, but will result in long-term benefits to water quality. As described in the 

NEPA documents for those projects, tidal restoration and removal of invasive and non-native 

vegetation may result in short-term soil erosion and increase the turbidity in waterways. 

Restoration activities such as breaches, the moving of fill, and dredging could result in temporary, 

short-term water quality impacts such as increased turbidity from soil erosion, sedimentation, and 

the introduction of contaminants carried by tidal waters entering refuge units. Mitigation 

measures adopted in the Records of Decision for the Bair Island and SBSP projects incorporated

best management practices that include the use of barriers to prevent sediment from flowing off 

the Refuge, thus minimizing impacts to water quality. 

In the long-term, restoration activities are expected to improve water quality by allowing tidal 

exchange of water. As a result of restoration, salinity and dissolved oxygen levels of water bodies 

on the Refuge would be regulated through regular tidal exchange. Restoration actions will also

draw sediment from waterways and the Bay into the refuge units to create land and eventually 

tidal marsh communities. However, the ongoing tidal restoration activities may also introduce 

contaminants into or out of the Refuge. The Refuge is researching contaminants issues in current 

tidal restoration projects to inform future management actions. Of particular concern is the 

distribution of legacy mercury now trapped in South Bay sediments and conversion of inorganic 

mercury to forms more bioavailable to wildlife. This could result in impacts to breeding success 

and longevity of certain species of wildlife.

Weed control activities in the form of mechanical, cultural, thermal, and chemical removal

methods may cause soil disturbance and will introduce chemicals into the environment. However, 

only approved herbicides appropriate for the Refuge’s upland and tidal marsh environments will 

be used according to label directions. Herbicide application will be permitted in or near water

bodies, but not during inclement weather to reduce impacts to water quality. All herbicides 

approved by the Service through the Pesticide Use Proposal (PUP) process would be applied at 

label rates and all label recommendations would be followed (e.g., measures to preclude herbicide 

application on windy days).

The Refuge would continue to periodically use Service-approved aquatic herbicides including: 

Round-up®, GlyproPlus, Aquamaster and Rodeo® (glyphosate), Garlon 4® (triclopyr), Habitat, 

Polaris (imazapyr), Milestone (aminopyralid) and Transline® (clopyralid) to control invasive 
B-43

plants on the Refuge. Glyphosate, the active ingredient in Rodeo, Roundup pro, and Roundup pro 

is considered nonmobile in soils and sediments because it rapidly and strongly adheres to soil 

particles and degrades in the soil. Glyphosate is moderately persistent in the soil. Glyphosate is 

highly adsorbed on most soils especially those with high organic content. More information on 

glyphosate is included in the soils section, above. 

Therefore, because glyphosate is so tightly bound to the soil and little is transferred by rain or 

irrigation water, it is not expected to affect water quality. One estimate showed less than 2 

percent of the applied chemical was lost to runoff (USFS 1984). The herbicide could move when 

attached to soil particles in erosion run-off. In water, glyphosate is strongly adsorbed to 

suspended organic and mineral matter and is broken down primarily by microorganisms. Its halflife in pond water ranges from 12 days to 10 weeks (Cornell University 1994). Because glyphosate 

is tightly bound to the soil and with the implementation of the Service’s PUP requirements, the 

Service anticipates there will be no adverse effects to water quality.

Triclopyr is not strongly adsorbed to soil particles, has the potential to be mobile, and is fairly 

rapidly degraded by soil microorganisms. Triclopyr was tested but not found in a host of 

groundwater sites throughout the country (Williams et al. 1988). The half-life of triclopyr exposed 

to sunlight is between 3 hours to 4.3 days. It degrades readily by photodegredation, but also by 

microbial metabolism and hydrolysis. Garlon 4 and Pathfinder II are not soluble in water, but 

Garlon 3A is highly soluble. It can be toxic to both fish and invertebrates (USFS 1996).

The half-life of clopyralid in water ranges from 8 to 40 days. It is highly water soluble and does 

not bind strongly to solids in water. Clopyralid degrades primarily through microbial metabolism. 

It can, however, contaminate ground and surface waters, but it is not toxic to fish, birds, or 

mammals (Tu et al. 2001).

The active ingredient in Milestone®, Aminopyralid is considered minimally to moderately mobile 

in soils, with a half-life of 103 days (WSDOT 2009). Given its high mobility, and moderate 

persistence in soil, aminopyralid is likely to leach to ground water, irrespective of soil type (U.S. 

EPA/OPP-EFED 2004 in SERA 2007). Additionally, this herbicide is considered non-toxic to 

slightly toxic to aquatic insects, such as dragonflies and water bugs (WSDOT 2009).

Imazapyr is the active ingredient found in herbicides such as Habitat® or Polaris®. It is highly 

soluble in water. The half-life of Imazapyr in water is 3-5 days with photodegredation being the 

primary form of degradation. Due to its rapid photodegradation by sunlight, water contamination 

by imazapyr is generally not of concern. (Leson and Associates 2005) 

Mosquito management activities (i.e., mosquito population monitoring, disease surveillance, and 

habitat improvements) are not expected to negatively impact water quality. Population 

monitoring and disease surveillance does not involve access or application of materials into 

waterways. Physical improvements such as ditching conducted by the mosquito abatement 

districts may cause temporary soil disturbance, but are expected to improve hydrology and overall 

water quality in areas with stagnant water issues. Best management practices will be 

implemented to reduce water quality impacts, such as avoiding ditch work during inclement 

weather and constructing barriers to prevent impact to waterways. Also, only biological and 

chemical mosquito controls approved for use will be permitted in aquatic areas (see Table 2 for a 

list of mosquito control pesticides currently approved). All mosquito controls approved by the 

Service through the Pesticide Use Proposal (PUP) process would be applied at label rates and all 
B-44

label recommendations would be followed (e.g., measures for aquatic environments).

Alternative A

Under Alternative A, the Bair Island and SBSP restoration projects would continue to move 

forward, and the effects on water quality and contaminants would be the same as described under 

Common to All Alternatives.

Alternatives B and C

Alternatives B and C would result in similar effects described in Alternative A. Additional 

hydrological improvements at La Riviere Marsh, Mayhews Landing, and New Chicago Marsh

may result in increased water turbidity from soil erosion in the short-term. In the long term,

water quality such as salinity and dissolved oxygen will be improved through regular tidal 

exchange and reduction of water impoundments at these sites. As restoration alternatives at La 

Riviere Marsh, Mayhews Landing, and New Chicago Marsh are developed, a site specific analysis 

will be completed, including a NEPA document. Best management practices will be implemented 

to reduce water quality impacts, such as avoiding restoration activities during inclement weather 

and constructing barriers to prevent impact to waterbodies.

Increased weed control efforts may result in greater temporary water quality impacts such as 

introduction of herbicides and soil erosion into waterways and the Bay. However, only herbicides 

approved for use in aquatic environments will be permitted.

Construction of nesting islands may also result in minor, short-term turbidity in managed ponds. 

Best management practices will be implemented to reduce water quality impacts, such as avoiding 

construction activities during inclement weather and constructing barriers to prevent impact to 

waterbodies. Contaminants monitoring in Alternative C will benefit water quality knowledge and 

management. Also under this alternative, by working with partners, the Refuge will improve its 

knowledge and management of contaminants such as mercury.

Soils and Topography

Common to All Alternatives

Ongoing tidal restoration activities implemented as part of the Bair Island and SBSP restoration 

projects will result in changes or disturbance to soil and topography of the Refuge. Restoration 

activities will increase sedimentation in some areas of the Refuge and reduce sedimentation in 

other areas, changing the topography of sites. The construction of nesting islands and other 

additional habitat will result in changes to pond topography to the benefit of shorebirds and 

waterfowl. Some areas may encounter increased sedimentation, while sediment loss may occur in 

other areas depending on tidal flows. 

Impacts to soils during ongoing operation and maintenance of Refuge land would come primarily 

from weed control. Weed control activities in the form of mechanical, cultural, thermal, and 

chemical removal methods may result in varying levels of soil disturbance and will introduce 

herbicides into the environment. Invasive plant removal may also result in temporary soil erosion, 

but these areas will be re-planted with native plants which should reduce long-term erosion 

potential. As part of weed control efforts, immediate best management practices to mitigate for 

soil erosion include constructing fencing or using hay bales to prevent soil from escaping the area. 
B-45

The Refuge would continue to periodically use Service-approved herbicides including:

Round-up®, GlyproPlus, Aquamaster and Rodeo® (glyphosate), Garlon 4® (triclopyr), Habitat, 

Polaris (imazapyr), Milestone (aminopyralid) and Transline® (clopyralid) to control invasive 

plants on the Refuge. The interaction of herbicides with soils affects the chemical’s availability to 

interact with water, fish and wildlife. The active ingredient for each pesticide and its availability 

in the soil is presented below. How herbicides interact with the soil affects its availability to 

potentially effect wildlife and fish, as discussed under the Wildlife and Fish sections below. 

Glyphosate is considered nonmobile in soils and sediments because it rapidly and strongly adheres 

to soil particles and degrades in the soil. Glyphosate is moderately persistent in the soil. 

Glyphosate has no known effect on soil microorganisms. Glyphosate is highly adsorbed on most 

soils especially those with high organic content. The compound is so strongly attracted to the soil 

that little is expected to leach from the applied area. Microbes are primarily responsible for the 

breakdown of the product. The time it takes for half of the product to break down (half-life) 

ranges from 1 to 174 days (USFS 1984). The herbicide could move when attached to soil particles 

in erosion run-off. In water, glyphosate is strongly adsorbed to suspended organic and mineral 

matter and is broken down primarily by microorganisms (Cornell University 1994). With the 

implementation of the Service’s PUP requirements, the Service anticipates there will be no 

adverse effects to soils or soil microorganisms.

The half-life of triclopyr in soil is from 30 to 90 days, depending on soil type and environmental 

conditions, with an average of about 46 days. The half-life of one of the breakdown products 

(trichloro-pyridinol) in 15 soil types (similar to those at the Refuge) ranged from 8 to 279 days 

with 12 of the tested soils having half-lives of less than 90 days. Longer half-lives occur in cold or 

arid conditions (Cornell University 1993). Clopyralid has a very high potential of mobility in soil. 

The half-life of clopyralid in soil is greater than 12 years and in water is 261 days. Under aerobic 

soil conditions, the half-life is 71 days. In the soil, clopyralid has a half-life of 8 to 66 days. 

Degradation is faster in warm, moist conditions and slower in cold, dry conditions. It degrades in 

the environment through the activity of soil microbes. Bioconcentration potential is low and 

biodegradation under aerobic lab conditions is below detectable levels. Transline is low in toxicity 

to mammals, birds, fish and bees (Dow AgroSciences 2003a, 2003b). 

The active ingredient in Milestone®, Aminopyralid is considered minimally to moderately mobile 

in soils, with a half-life of 103 days (WSDOT, 2009). Due to this transport ability, the amount of 

herbicide expected to transport from the upland areas into the wetland/riparian areas is expected 

to be insignificant (Koopmann & Andersen 2009 in WSDOT 2009). 

The herbicides Habitat® and Polaris® which contain Imazapyr, are considered highly mobile in 

soils with a half-life of 25-141 days depending on water inundation. Imazapyr is relatively mobile 

in soils because it adsorbs to soils and sediments only weakly. Adsorption increases with 

decreasing pH. Above a pH of 5, imazapyr is ionized and does not adsorb to soil. Volatilization of 

imazapyr from soil is insignificant. The mobility of Imazapyr in soils is of small concern however, 

as it does not bio accumulate and is considered practically non-toxic to mildly toxic to mammals, 

birds, fish, and aquatic invertebrates (Leson and Associates 2005).

Both restoration and weed control are expected to result in temporary impacts to soil while 

providing long-term stability to soil regimes on the Refuge with the replacement of native 

vegetation.
B-46

Mosquito management activities (i.e., mosquito population monitoring, disease surveillance, and 

habitat improvements) are not expected to negatively impact soil and topography. These activities 

are primarily done on foot by a few individuals. Use of trucks and ARGOs (all-terrain vehicle) 

would be restricted to levees and established berms. Only small all-terrain vehicles will be 

permitted around vernal pools, and because of their weight, are unlikely to impact topography or 

soil. Physical improvements such as ditching conducted by the mosquito abatement districts may 

cause temporary soil disturbance, but are not expected to result in major soil loss or change in 

topography.

Alternative A

No new projects would be developed under Alternative A, so the effects on topography and soils 

would be the same as described under Common to All Alternatives.

Alternative B

Under Alternative B, additional restoration sites would be assessed and enhanced at La Riviere 

Marsh, Mayhews Landing, and New Chicago Marsh sites, as needed. This restoration effort will 

result in localized soil erosion or sedimentation in the short-term, which would be offset by the 

formation of tidal marsh plant communities that will stabilize soil topography in the long-term. 

Native plant restoration of the Faber-Laumeister, La Riviere, EEC, Pond A6, and Pond A8 

marsh-upland ecotone (levees) will result in short-term, localized soil disturbance through hand 

planting of native plants, but will stabilize soil in the long term. More intense weed control efforts, 

such as prescribed burns, may result in additional soil disturbance and erosion, but would be offset 

by avoiding areas at high risk of erosion and planting controlled areas with native plants. Under 

this alternative, high marsh and ecotone/transition zones will be heightened where possible using 

additional fill material, resulting in changes to soil topography. Localized soil disturbance will 

occur with the placement of fill material, but the formation of plant communities on these filled 

areas over the long-term is expected to stabilize soils.

Increased soil disturbance and erosion will occur in varying degrees from improvements to 

existing and placement of new visitor amenities (i.e., signage, bus stop, remote camera system, 

kayak/canoe boat launch, photography blind, boardwalk, fishing platform/pier, geocache sites, 

earth cache sites, and visitor center complex). Localized soil disturbance (e.g., compaction and 

erosion) will occur from the use of motorized heavy equipment and foot traffic to place this 

infrastructure. The placement of these features will be assessed individually; infrastructure will 

not be placed in sensitive habitat and sites that may be at high risk for soil erosion. 

Climate change modeling in Alternative B would inform management activities to adapt to future 

changing conditions. For example, modeling results will inform refuge staff where changes to soil 

and topography conditions (e.g., conversion of tidal marsh and mudflats to open water) are 

expected as a result of sea-level rise. Modeling will help identify specific needs for where 

acquisition of mudflat, marsh, and uplands should take place.

 

Additional wildlife-oriented recreation, interpretation, environmental education, and volunteer

opportunities under this alternative will result in additional foot traffic on the Refuge. Increased 

visitation may also result in soil disturbance. To reduce soil impacts, increased signage and staff

training to contact visitors will be used to encourage visitors to stay on trails and avoid sensitive 

habitats. 
B-47

Alternative C

Activities conducted in Alternative C would result in similar effects as Alternative B. In addition 

to these effects, there would be additional short-term soil disturbance from native plant

enhancement and restoration of the marsh-upland ecotone along all levees in the Ravenswood and 

Alviso pond systems, which would be offset by the formation of native plant communities. More 

aggressive weed control efforts would result in greater potential for soil disturbance. Like 

Alternative B, these activities would be mitigated by avoiding areas at high risk of erosion and 

planting disturbed areas with native plants.

Air Quality 

Common to All Alternatives

The Bay Area Air Quality Management District (BAAQMD) regulates air quality standards in the 

region. All ongoing restoration-related construction and general operation and maintenance

would have temporary increases in dust (PM10) from earth moving activities and tailpipe 

emissions (e.g., nitrous oxides, sulfur oxides, carbon dioxide) from vehicle use. Prescribed burns 

for weed management will also result in temporary, localized increases in smoke and particulate 

matter. The Refuge will obtain any necessary permits from the BAAQMD prior to all prescribed 

burns. These activities temporarily affect air quality in the local area. On average, burns would 

be conducted no more than once every three years. Also, most visitors to the Refuge arrive by 

motorized vehicles which would result in particulate emissions as well. Mitigation measures 

related to ongoing restoration work are described in the EIS/EIRs for the Bair Island and SBSP 

restoration projects.

General operation, maintenance, management, and visitor activities would not substantially affect 

air quality. Operation and maintenance activities are generally limited to driving on existing 

roads and levee crowns as well as localized levee repair work. It is reasonable to assume that an 

increase in visitor use at the Refuge may reflect visitors choosing the Refuge as their destination 

rather than another location offering similar opportunities in the San Francisco Bay area (such as

East Bay Regional Park System, in proximity to the Refuge). For this reason, the Service 

anticipates that there would be few to no new vehicle trips, but if there is an increase in tailpipe 

emissions resulting from increased visitor opportunities, it is likely to be negligible. 

Alternative A

Alternative A would have the same effects on air quality and climate as described under Common 

to All Alternatives.

Alternatives B and C

Implementing tidal enhancement activities (at La Riviere Marsh, Mayhews Landing, and New 

Chicago Marsh) under Alternatives B and C will increase localized and temporary dust (PM10) 

and tailpipe emission from heavy equipment operation. Construction of additional public use 

infrastructure such as trails and fishing platforms will also increase localized dust particles from 

vehicle emissions. Again, these activities are expected to be infrequent, one-time projects with 

short-term increases to air emissions. Measures to mitigate for dust include avoiding activities 

during extreme dry seasons or wetting down soil during construction activities to reduce dust. As 

the details of these restoration projects are developed, specific mitigation measures will be 

developed.
B-48

In addition to construction, increased biological surveys and research are anticipated under 

Alternatives B and C, and would result in short-term, minor increased tailpipe emissions.

More aggressive weed control activities under Alternatives B and C may result in temporary and 

minor increases in localized particulate matter. Mechanical control (e.g., pulling, mowing, disking) 

will result in temporary, localized increases in fugitive dust and increases in tailpipe emissions 

when heavy equipment is used. Herbicide application is not likely to affect air quality. 

Application of chemicals to control non-native vegetation would not occur during inclement 

weather such as high winds to avoid the possibility of chemical drift. Also, herbicide would be 

applied in close contact to the plant, either via backpack sprayer or truck/ATV-mounted tanks. 

Expanding the prescribed burn season from the current September 1-October 15th to June 15th – 

October 15th in Alternatives B and C may result in temporary effects to air quality. Thermal weed 

control (i.e., prescribed burns) may be utilized more under Alternatives B and C and would likely 

increase particulate matter. However, burns would only occur approximately once every three 

years on average on areas no larger than 50 acres. Prior to burns, permits will be obtained from 

the BAAQMD to comply with air quality requirements and determine best management practices. 

These may include restrictions on igniting under certain wind speeds/directions, humidity, or 

other conditions that would cause local air quality to be degraded. The selection of, and adherence 

to a proper prescription, and careful coordination with the BAAQMD, Alameda County Fire 

Department, and the Service Regional Fire Management Officer will greatly limit the chance of 

an extreme intensity burn. 

Alternatives B and C are designed to increase visitation (from 750,000 to at least 1,000,000 visitors

annually) to the Refuge and thus will create overall long-term increases in tailpipe emissions to 

the area. However, these increases are not expected to significantly affect the overall air quality 

of the area. It is reasonable to assume that an increase in visitor use at the Refuge may reflect 

visitors choosing the Refuge as their destination rather than another location offering similar 

opportunities in the San Francisco Bay area (such as the East Bay Regional Park System, in 

proximity to the Refuge). For this reason, the Service anticipates that there would be few to no 

new vehicle trips, but if there is an increase in tailpipe emissions resulting from increased visitor 

opportunities it is likely to be negligible. Further, if a bus stop can be constructed at the 

headquarters (Alternative B) and EEC (Alternative C), individual vehicle trips to the Refuge 

could be reduced. Overall, increased management and visitor activities prescribed in Alternatives 

B and C are not expected to affect Refuge resources or regional ambient air quality.

Hazardous Materials and Safety Issues

Common to All Alternatives

Under all the alternatives, herbicides and pesticides are the only known hazardous materials that 

will be used on the Refuge. Pesticides and herbicides are selected based on human safety, 

environmental integrity, effectiveness, and cost. Pesticides and herbicides used on the Refuge 

must go through a rigorous review process and have completed necessary environmental 

documentation and procedures (e.g., pesticide use proposal). Because of this review process, 

selected pesticides and herbicides are not expected to result in any significant impacts to the 

Refuge or local environment. Herbicide will be stored in an approved spill-proof locker, according 

to label directions, California regulations, and Service policy. Crews applying the herbicide will be 

trained in storage and application to these same standards. Pesticide application for mosquito 

control will be conducted by trained personnel from local mosquito abatement districts. In the 

long-term, the use of herbicides is expected to decrease with the reduction of non-native
B-49

vegetation. Use of pesticides is expected to decrease with wetland enhancements. The current 

pesticides and herbicides approved for use on the Refuge are listed in Table 2. 

Table 2. Current Pesticides and Herbicides Approved for Use on the Refuge (2012)

Pesticide or Herbicide Name Purpose

VectoLex WDG, VectoLex CG, VectoLex WSP Mosquito control

VectoBac G, VectoBac 12AS, Teknar HP-D, 

VectoBac WDG

Mosquito control

Bactimos pellets, Summit B.t.i. Briquets Mosquito control

Altosid Pellets WSP, Altosid Briquets, Altosid XR 

Extended Residual Briquets, Altosid XR-G, Altosid 

Liquid Concentrate SR-20

Mosquito control

Altosid Liquid Larvicide Mosquito Growth 

Regulator

Mosquito control

Pyrenone 25-5 Mosquito control

Agnique MMF Mosquito control

Mosquito Larvicide GB-1111(Clark) Mosquito control

Aquamaster, Rodeo Weed control

Milestone VM Plus Weed control

Roundup Pro, Glypro Plus Weed control

Garlon 4 Weed control

Habitat, Polaris AQ, Polaris Weed control

Transline Weed control

Ongoing tidal restoration projects may mobilize the contaminants (e.g., mercury) found in the soils 

on the Refuge. Removal of levees to increase tidal circulation may facilitate the movement of 

contaminants to different areas of the Refuge or possibly off the Refuge into navigable waters. 

Monitoring is included as a component of the restoration activities to understand the movement of 

contaminants and adapt to any necessary changes to eliminate or reduce their mobilization. The 

Refuge staff would work with partners to monitor priority species for priority contaminants 

known to be in the Bay, such as mercury and polychlorinated biphenyls. 

Alternatives A and B

Alternatives A and B would have the same effects on as described under Common to All 

Alternatives.

Alternatives C

Under this alternative, the Refuge staff would increase efforts with partners to monitor priority 

species for priority contaminants known to be in the Bay, such as mercury and PCBs. 

Contaminant threshold levels will also be developed for priority species. Our Refuge management 

activities would benefit from knowledge gained through these studies.

Wilderness

Because there is no designated wilderness at the Refuge, none of the alternatives will impact 

wilderness.
B-50

Biological Resources

Vegetation and Habitat

Common to All Alternatives

Operation and maintenance activities conducted under each alternative would have a beneficial 

impact to native plants. Weed control activities in the form of mechanical, cultural, thermal, and 

chemical removal methods will allow native plant communities to thrive with less competition from 

invasive weeds. Mechanical, cultural, and thermal weed control may also result in indirect effects 

to native plants. Small, discrete patches of native plants may be temporarily disturbed or 

trampled by heavy equipment, foot traffic, and grazing by cows. Although it has only been six full 

years of monitoring since grazing has been reintroduced, the results of the grazing analysis 

support that grazing at Warm Springs has contributed to the achievement of the program’s tenyear goals (WRA 2011). Grazing has substantially reduced residual dry matter (dead plant 

material), increased native species cover, and maintained CCG populations and low invasive 

species cover. 

Grazing is expected to continue to result in beneficial effects to native vegetation. Primary 

benefits associated with the grazing program include a reduction in the accumulation of dead plant 

material. This residual dry matter, or RDM, is measured annually at the end of the growing 

season to assist in monitoring the grazing program. High RDM values, which consist primarily of 

non-native annual grasses, have been associated with reduced native plant diversity in vernal 

pools (Barry 1998). By preferentially consuming the taller, more palatable non-native grasses, 

cattle effectively increase light and nutrient availability for the native forbs during a key stage in 

their development. RDM measurements at Warm Springs have gone from approximately 5,000-

6,000 pounds per acre in the absence of grazing to approximately 1,250-3,000 pounds per acre in 

2009 and 2010 (the last two years of data). 

Prior to the reintroduction of grazing, there was concern that grazing could negatively impact 

vernal pool vegetation, particularly the endangered CCG. However, cattle are known to 

selectively forage on grasses (Kie & Boroski 1996; Stoddart et al. 1975) and help maintain a more 

open canopy (Weiss 1999) which benefits native vernal pool plants. Refuge staff has similarly 

observed that cows have shown a substantial preference for grazing on grasses and wild mustard 

over native vernal pool plants (I. Loredo, pers. comm., 2011). Also, experimental grazing 

exclosures within vernal pools have consistently shown that grazing reduces cover of non-native 

annual grasses and increases cover of native vernal pool forbs (see USFWS Annual Reports 2006-

2011). Ungrazed plots are dominated by non-native annual grasses, while grazed plots have, on 

average, 2.5 times higher cover of native vernal pool plants (WRA 2011). As for upland plants, 

Refuge data show that grazed pasture have consistently higher cover of native plants than 

ungrazed pastures (WRA 2011). Grazing will be closely monitored and managed so that individual 

pastures are grazed at target stocking rates. Stocking rates have been determined through 

pasture-specific productivity measurements and target RDM values and can be adjusted based on 

annual climatic conditions. The Refuge has flexibility in increasing or decreasing stocking rates 

by working with the cooperative grazer to decide how many cows to sell each year. Water troughs 

are available in each pasture in the upland habitat to ensure that cows do not use the vernal pools 

as a water source and to therefore minimize effects to CCG and other vernal pool plants. 

Prescribed burning will result in charring of vegetation, predominantly invasive vegetation, but 

may include some native vegetation. Burn areas are expected to be small, less than 50 acres in 
B-51

size. However, the soil would be enriched by the burn, promoting rapid recovery of the areas. It 

is not expected that chemical control of weeds will impact native plants. 

The application of herbicides will be properly calibrated to needs. Only trained applicators would 

apply herbicides, following label rates and other instructions per the Refuge’s approved PUPs. 

Timing of application would take into account wind speed and moisture in the air to reduce the 

potential of transfer of herbicide to non-target plants. Use of herbicides would result in reduced 

non-native vegetation and allow for expansion of native plant communities. For any weed control 

activities, endangered plants will be flagged and avoided. Planting of native plants will also 

facilitate native plant communities. Refuge staff would use different planting pallets and compare 

results to determine how best to encourage the growth of native plant communities. Overall, weed 

control is expected to result in a net benefit to native vegetation. Other operation and 

maintenance activities would have minor local effects to vegetation. Repairing water control 

structures would take place in areas that are already disturbed and colonized by non-native 

vegetation. Monitoring, survey, and research activities (e.g., Warm Springs vernal pool surveys) 

would result in some trampling of vegetation, but these impacts would be limited and temporary.

Habitat restoration fulfills the Service’s congressional mandate to preserve, restore, and enhance 

habitat for threatened and endangered species, songbirds, waterfowl, other migratory birds, 

interjurisdictional fish, marine mammals, resident wildlife, and plants. The ongoing plant and 

habitat restoration activities will result in the loss of seasonal freshwater wetland and upland 

habitat, but will result in an increase in tidal marsh habitat and enhancement of existing tidal 

marsh habitat. 

Impacts to vegetation could occur during access (on-foot, ARGOs) within tidal marsh to conduct 

mosquito management. The use of mechanized vehicles that traverse wetland areas (ARGOs and 

ATVs) have a much greater impact on vegetation than foot access, including the trampling of 

plants. However, these vehicles have low ground pressure (minimal pound per square inch) and 

not expected to completely crush any plants. To reduce impacts to vegetation, mechanized 

vehicles will only be allowed on levees and existing roads unless approved by the Refuge manager. 

Techniques for approved ARGO operations will be used to limit impact, including: slow speeds; 

slow, several point turns; and using existing levees or upland to travel through sites when 

possible. Mosquito management activities could also spread or introduce non-native vegetation 

(through footwear, clothing, vehicle tires). To reduce the spread of non-native, invasive plants all 

construction equipment, vehicles and personnel gear must be cleaned of any possible seeds, soil or 

plant material before arriving on site.

The application of other pesticides, including adulticides, are not likely to adversely affect 

vegetation directly because the pesticides used for mosquito control are not known to harm plants. 

Pyrethrins are not expected to affect plants because the sodium channel mechanism of action for 

pyrethrins does not indicate that pyrethrins would be toxic to plants (USEPA 2006). As a 

precaution, pesticides will be applied according to pesticide label instructions and per habitat type.

Impacts to Refuge vegetation by current wildlife-oriented recreation opportunities (e.g., wildlife 

observation, photography, fishing, and hunting) is expected to be insignificant. Hunting is 

permitted on foot and by boat, but because the hunter population is relatively small, impacts to 

vegetation from this type of use is expected to be minimal. There is an average of 2,000 hunt visits 

annually on 7,500 acres of Refuge open to hunting that provides ample hunt acreage per hunt visit. 
B-52

Access to hunt areas primarily takes place via existing levees, further minimizing disturbance to 

wetland areas. Also, use of hunt blinds deters hunters from disturbing vegetated areas. Fishing 

is expected to have minimal impact to vegetation. Fishing is allowed only in designated areas, 

such as the shoreline at Faber-Laumeister and the fishing pier at headquarters. Vegetation in 

these areas may be trampled, but is a small, localized impact compared to the size of the Refuge. 

Designated trails provide access to shoreline fishing areas; both the trails and fishing are 

generally packed dirt with little vegetation. 

Like fishing, wildlife observation and photography are permitted on designated trails and 

overlook areas. However, discrete areas of vegetation may be trampled by visitors wandering 

away from designated areas. Trampling is expected to be temporary and small-scale. 

Interpretation and environmental education programs may have a negligible impact to vegetation. 

These programs are conducted in small groups and generally occur on trails and other designated 

areas for visitors. Small, discrete vegetated areas may be temporarily trampled during programs, 

but they are not expected to be significant impacts. In addition, these programs will be guided or 

supervised to ensure that visitors remain in designated areas and avoid sensitive habitat.

Alternative A

Alternatives A would have the same effects on vegetation and habitat as described under Common 

to All Alternatives.

Alternative B

In addition to the activities proposed in Alternative A, Alternative B would result in additional

enhancements to existing tidal marsh to improve habitats and vegetation at subunits, including La 

Riviere Marsh, Mayhews Landing, and the New Chicago Marsh sites. Portions of these areas 

currently have low quality marsh plants due to poor water circulation. Specific enhancements 

have not yet been identified, but potential methods could include lowering of levees and creating 

breaches. These actions are not expected to replace one habitat type with another, but instead 

enhance tidal circulation in the tidal marsh habitat to improve vegetation for tidal marsh species. 

Under this alternative, high marsh and ecotone/transition zones will be heightened and expanded 

where possible, ensuring high tide refugia for tidal marsh wildlife. As site specific designs are 

developed at these other marsh areas, further NEPA documentation will be completed.

Under this alternative, a weed management plan will be implemented to control invasive weeds. 

Unlike current weed management activities that occur without planning and as resources allow, 

the plan will focus control efforts on priority weeds that out-compete native vegetation. The 

impacts of the control efforts are similar to those previously described in Common to All 

Alternatives. Ecotone/transition zones will benefit under this alternative, as most priority weeds 

are located in this habitat type and because they are prone to introduction of weeds from the 

general public, particularly at Faber-Laumeister, La Riviere Marsh, EEC, Pond A6, and Pond A8. 

A re-vegetation plan will also facilitate the formation of native plant communities.

Under this alternative, grazing at Warm Springs would occur among the entire 700 acres that will 

soon be managed solely by the Refuge. The addition of 444 acres of the former Pacific Commons 

Preserve (currently managed by ProLogis as part of a mitigation project) and a previously 

ungrazed pasture on Warm Springs to the grazing program will provide enough pastures among 

which to rotate cattle. Grazing is expected to continue to result in beneficial effects to native 

vegetation, as detailed above in the “Common to All Alternatives” section. In a large-scale vernal 
B-53

pool grazing study, the continuously grazed pools had the highest relative cover of native species 

across all 3 years of the experiment, higher than both the ungrazed and seasonally grazed 

treatments (Marty 2005); similarly, Robins and Vollmar (2001), in a comprehensive review of 

grazing in vernal pool habitats, concluded that CCG populations thrived in regularly grazed or 

mowed sites and that ungrazed sites generally had smaller populations. Increased vegetation 

management activities at Warm Springs may cause increased disturbance through the use of 

mechanical, manual, and chemical control methods. However, control methods will continue to be 

managed properly in order to minimize impacts to native vegetation, and are expected to have an 

overall positive impact on native species. These activities, along with seeding, are expected to 

reduce non-native vegetation competition and allow native vernal pool/grassland vegetation 

species to thrive.

Also under this alternative, prioritization of remaining lands within the approved acquisition 

boundary and a more active role in acquiring these lands (from willing sellers) will be beneficial to

habitat types that are most vulnerable to loss (e.g., tidal habitat) as a result of sea-level rise from 

climate change.

Coordination with the Service’s LCC and I&M efforts to address near-term and long-term climate 

change impacts under this alternative will have added benefit to vegetation. Through 

understanding climate change impacts to the Refuge habitats, staff will identify adaptive changes 

or acquisition needs that may be required to support changing habitat. The process will help staff 

identify which habitats are most at risk of climate change effects and prioritize management 

actions to protect them. 

The placement of public infrastructure, such as a visitor center complex, fishing platforms, 

signage, and interpretive panels will result in the loss of some vegetation. Loss of vegetation 

would be minimized to the small size of the construction footprint (less than one acre in total). 

Also, the infrastructure will not be placed in sensitive areas. 

Additional visitor opportunities will have both negative and positive impacts on vegetation. 

Increased activities will result in additional visitors and more pressure on the habitat. More 

visitors may result in increased trampling of vegetation. However, staff contact, law enforcement, 

and signage will be increased to encourage visitors to stay in designated areas and out of sensitive 

habitats. Also, boardwalks and platforms will be installed to protect vegetation from trampling. 

Increased visitation of the Refuge may increase stewardship and support for native habitats.

The additional environmental education and volunteer opportunities prescribed under Alternative 

B will also benefit Refuge habitat and vegetation. The Restoration Education program and 

volunteers will benefit habitats through native plant propagation, weeding of non-native

vegetation, and planting of native plants. Sensitive wildlife areas will be avoided. The benefit may 

extend beyond the Refuge itself; when visitors become informed of the advantages of native 

vegetation, they may begin to plant natives on their own property.

Hunting activities are not expected to be increased and therefore are not expected to impact 

vegetation. Constructing fishing platforms and associated infrastructure will result in the loss of 

habitat and vegetation at Coyote Creek and Faber-Laumeister. It is anticipated that less than a 

0.25 acre of habitat will be lost to the development of these fishing areas. Upland ruderal 

vegetation will be selected to reduce impacts on sensitive wildlife. Fishing participation is 
B-54

expected to increase as a result of fishing pier renovation and additional fishing locations. This 

may result in additional trampling of vegetation, but this impact is expected to be temporary and 

minimal in nature. Furthermore, designated platforms can reduce trampling of vegetation by 

confining the fishermen to the fishing platforms rather than allowing them to walk along the 

banks with native vegetation.

Alternative C

In addition to the activities proposed in Alternative B, Alternative C would result in additional 

enhancements to existing tidal marsh to improve habitats and vegetation at the Faber-Laumeister 

and Munster sites. Specific enhancements have not been identified yet, but potential methods 

could include lowering of levees and creating breaches. These actions are not expected to replace 

one habitat type with another, but instead enhance tidal circulation in the tidal marsh habitat to 

improve vegetation for tidal marsh species.

Under this alternative, weed control efforts will be increased that will allow native vegetation to 

thrive. The impacts of the control efforts are the same as those previously described in Common 

to All Alternatives. Ecotone/transition zones will benefit from action under this alternative, 

particularly along Ravenswood and Alviso Ponds.

The placement of additional public infrastructure, such as a boat launch, additional signage, EEC

bus stop, walking path/bridge, water trail stop, auto tour route, geocache, earth cache, hunt blinds, 

and nature exploration area at the EEC will result in the loss of some vegetation. Loss of 

vegetation would be minimized to the small size of the construction footprint (not more than one

acre in total). Also, the infrastructure will not be placed in sensitive areas. The opening of an 

additional 340 acres of ponds to waterfowl hunting may cause trampling of vegetation by foot and 

by boat. In addition, other increased visitor amenities may increase visitation numbers, which 

may also result in increased trampling of vegetation. However, these impacts are expected to be 

temporary in nature. Visitors will also be directed by signage and staff to designated public areas. 

Signage will indicated sensitive, closed areas. The Restoration Education program will be 

expanded to include an additional site on Bair Island.

Hunting activities will be expanded by 340 acres and may result in increased trampling of

vegetation. The construction of a universally-accessible hunt blind will also result in a small loss of 

habitat and vegetation. This blind will be placed where there is the least amount of impact to 

sensitive habitat. Constructing fishing platforms and associated infrastructure will result in the 

loss of habitat and vegetation at Coyote Creek and Faber-Laumeister. It is anticipated that less 

than a 0.25 acre of habitat will be lost to the development of these fishing areas. Upland ruderal 

vegetation will be selected to reduce impacts on sensitive wildlife. Fishing participation is 

expected to increase as a result of fishing pier renovation and additional fishing locations. This 

may result in additional trampling of vegetation, but this impact is expected to be temporary and 

minimal in nature.

Wildlife

Common to All Alternatives

Any restoration projects would result in short-term impacts and long-term benefits for wildlife 

species as described in the EIS/EIRs for the Bair Island and SBSP projects. As described in the 

previous environmental documents, all construction activities would occur during daylight hours 

only (unless pre-approved by the Refuge Manager), allowing wildlife resting periods at night. 
B-55

Wildlife could be temporarily flushed by construction activities (e.g., heavy equipment operation, 

foot traffic) associated with restoration and enhancement projects. These projects would also 

result in loss of diked upland habitat when they are exposed to tidal action. Upland species such 

as mammals, raptors, and songbirds will be permanently displaced as it evolves into a tidal marsh 

that will support CLRA, SMHM, and other marsh species. Conservation measures will be 

employed, such as avoiding sensitive breeding seasons; surveying areas before activities take 

place; and trapping, relocating, and fencing before activities begin. In the long-term, however, 

these areas are expected to accrete and create higher quality tidal marsh habitat. These activities 

would result in short-term disturbance to wildlife, but are not expected to result in populationlevel effects and would be outweighed by the creation of additional native habitat for wildlife or 

outreach through its environmental education and interpretation programs. As future restoration 

projects are identified, additional site specific NEPA documents will be completed.

Weed control and wildlife surveys could also disturb wildlife. Foot traffic and motor vehicle 

operations for these activities could temporarily flush wildlife. These operations would only occur 

during daylight hours and are expected to occur in small, discrete areas. Native plant restoration 

will directly cause disturbance in wildlife habitat and may temporarily flush wildlife. Manual and 

chemical removal of invasive weeds may adversely affect individuals, but not negatively affect 

wildlife populations because weeds are generally not considered habitat for native wildlife species. 

The Refuge would continue to periodically use Service-approved herbicides including: Roundup®, GlyproPlus, Aquamaster and Rodeo® (glyphosate), Garlon 4® (triclopyr), Habitat, Polaris 

(imazapyr), Milestone (aminopyralid) and Transline® (clopyralid) to control invasive plants on the 

Refuge. Triclopyr is low in toxicity when eaten by animals (NPIC 2002). Testing was documented 

on mammals such as rats and guinea pigs. Triclopyr is slightly to practically non-toxic to birds; 

depending on the species; and practically non-toxic to bees (NPIC 2002). 

The Environmental Protection Agency (EPA) classification for Aminopyralid is toxicity category 

IV; the lowest toxicity category a chemical can receive (Dow AgroSciences 2006). Aminopyralid is 

considered practically non-toxic to mammals, bird species, bees, and fish. Additionally, this 

herbicide is considered non-toxic to slightly toxic to aquatic insects, such as dragonflies and water 

bugs Bioconcentration potential for Milestone® Herbicide is low. While indirect exposures to 

wildlife may occur, Aminopyralid is considered practically non-toxic and impacts to wildlife will be 

minimal should it come into contact with this herbicide (WSDOT 2009). 

Based on U.S. EPA ecotoxicity criteria, Imazapyr is generally considered practically non-toxic to 

mammals, many birds, and bees. Toxicity rates among fish and aquatic invertebrates are 

considered low and within safe parameters according to standards established by the EPA. There 

is a lack of information on the toxic effects these herbicides have on reptiles, amphibians, raptors, 

and shorebirds (Leson and Associates 2005). 

It is expected that the grazing program will continue to improve habitat for VPTS and CTS by 

increasing maximum pool depths and inundation times. In a published study using a controlled 

large-scale experimental design, it was demonstrated that year round grazing in vernal pools 

increased pool inundation times and aquatic invertebrate diversity when compared to seasonal 

grazing or complete rest from grazing (Marty 2005). Due to their high productivity, non-native 

annual grasses produce heightened levels of plant biomass along vernal pool edges as compared to 

native vernal pool species. As it accumulates, this organic matter decreases the net amount of 

water available for native species by increasing evapotranspiration rates, resulting in an overall 
B-56

reduction in pool inundation period (Bremer et al. 2001, Frank 2003). By consuming the organic 

matter before it accumulates, cattle minimize these negative impacts of non-native annual grasses 

(Barry 1998, Robins and Vollmar 2001). At Warm Springs, pool inundation time has been the 

most reliable indicator of which pools will support VPTS and CTS because these species need a 

minimum amount of time (several weeks to several months) to complete their aquatic life stage.

The potential negative effects of grazing on VPTS and CTS are generally the result of overgrazing and include excessive trampling in vernal pools, increased nitrogen addition to pools, and 

the potential for cattle to cause pools to dry early by drinking from them. These effects have been 

hypothesized or observed in overgrazed study sites but most researchers and land managers 

currently agree that some level of grazing is important for maintaining ecosystem health within 

vernal pools (Robins and Vollmar 2001). Grazing generally is compatible with the continued use of 

rangelands by the CTS as long as best management practices are followed, intensive burrowing 

rodent control programs are not implemented in these areas, and grazing is not excessive 

(USFWS 2009, Shaffer et al. 1993). At Warm Springs, the grazing program has been carefully 

managed to avoid over-grazing. The installation of 16 water troughs, placed in upland areas 

throughout Warm Springs, has been successful in preventing cattle from using pools as water 

sources (I. Loredo, pers. comm., 2011). Also, there is no evidence that grazing has negatively 

affected populations of VPTS or CTS at Warm Springs. In fact, since annual aquatic dip-net 

surveys began in 1999, the two best years for VPTS were in 2010 and 2011 and for CTS were in 

2008 and 2010 (USFWS 2011, USFWS 2010), long after the initiation of grazing. 

By reducing the thick layer of annual grass thatch, grazing may favor rodent species that require 

areas of open ground to forage and escape from predators (USGS 2001). There also appears to be 

a strong association between grazed communities, burrowing rodents, and the presence of tiger 

salamanders (DiDonato 2006). Since grazing was reestablished in 2004, the abundance of ground 

squirrel burrows has notably increased (I. Loredo, pers. comm., 2011). Ground squirrel burrows 

are known habitat for CTS during the non-breeding season (Loredo et al. 1996) and also provide 

habitat for the California burrowing owl. The presence of California ground squirrels may be the 

single most important determinant of whether burrowing owls use a given site (Barclay 2001). 

Although annual surveys for burrowing owls have not been regularly conducted at Warm Springs, 

burrowing owls have continuously been observed breeding at Warm Springs and annual 

monitoring of the adjacent Pacific Commons Area (prior to Refuge acquisition) demonstrated an 

expansion of the burrowing owl population (WRA 2007 and 2006). Indeed, properly managed 

livestock grazing has been shown to benefit burrowing owls (Kantrud and Kologiski 1982, 

MacCracken et al. 1985) and may favor other bird species as well, including ground-foraging birds 

such as killdeer and American Robin (Bock et al. 1993). 

Longer vernal pool inundation periods that result from grazing would also expand available 

habitat for shorebirds, wintering waterfowl, and neotropical migratory birds. Warm Springs 

supports breeding shorebirds and waterfowl, such as the American avocet, black necked stilt, 

killdeer, mallard, and Canada goose, that often begin nesting on vernal pool shorelines or islands 

while pools are still inundated (I. Loredo, pers. comm., 2011). 

Grazing can have both negative and positive effects on birds. In riparian areas and prairies, some 

species of nesting waterfowl and songbirds may be negatively impacted by grazing (Krueper 1993, 

Kirsch 1969). However, certain guilds of migratory shorebirds require short and/or sparse 

foraging habitat (Baker and Baker 1973; Helmers 1992). Colwell and Dodd (1995) found greater 
B-57

shorebird species diversity and abundance in grazed pastures in coastal California. Grazing at 

Warm Springs (already analyzed in a 2003 Environmental Assessment) produces a mosaic of plant 

heights and therefore continues to provide available habitat for grass-nesting species (I. Loredo, 

pers. comm., 2011). Grazing improves plant species composition and structure so that short-term 

or species-specific impacts to wildlife and habitat are expected to be mitigated by long-term 

benefits to Refuge vegetation, native plants, and overall wildlife habitat quality. 

Prescribed burns would flush wildlife and may result in temporary loss of habitat for some 

species, but prescribed burn areas are small in size and burning occurs infrequently on the 

Refuge, thus limited the impacts to wildlife. Prescribed burns would also result in reduced air 

quality and visibility for wildlife. The use of herbicides for controlling invasive vegetation is not 

expected to affect wildlife species. Herbicides will be applied by hand directly to plants to avoid 

non-target species. Sensitive breeding seasons and locations will be avoided. The use of 

herbicides and pesticides is highly regulated through the Service’s PUP process. This approach 

notes environmental hazards, efficacy, costs, and vulnerability of the pest. All herbicides 

approved by the Service through the PUP process would be applied at label rates and all label 

recommendations would be followed. Mitigation measures that may be employed include 

conducting surveys prior to removal activities to determine presence of nests or young. In the 

long-term, plant community restoration activities will benefit species by providing additional 

habitat.

The mammalian and avian predator management plans could result in loss of red fox, feral cat, 

rat, skunk, raccoon, common raven, American crow, California gull, red-tailed hawks, and 

northern harrier individuals. Other species may be taken as new data on predation becomes 

available. However, predator management will not result in a population-level effect on any of 

these species. Predator management activities may also indirectly disturb other wildlife. 

Installation of predator barriers may impede access for non-target species from entering or 

exiting their feeding, roosting, and breeding areas. Trapping activities may also flush or disturb 

non-target wildlife from their habitat. Nonetheless, predator management activities are expected 

to result in positive, long-term increases in migratory bird breeding success, recruitment, and 

total population size. 

Mosquito Management

Impact to mammals that use the Refuge may occur during the monitoring, surveillance and 

control of mosquitoes, as well as the application of pesticides. The SMHM occurs throughout tidal 

marsh of the Refuge. Adverse impacts to salt marsh mammals may occur as a result of marsh 

access via foot or mechanized vehicles for mosquito management activities and addressed in the 

following endangered species section. Vehicle effects on habitat include compacted soil and 

destroyed vegetation (Bias and Morrison 1993). In addition, repeated vehicle travel over the same 

areas can create paths through the pickleweed that increases access for predators. Vehicle travel 

can also disrupt daily activity (e.g. movements) of small mammals and has the potential to cause 

mortality of individuals. In addition, boat, ARGO and foot travel can flush harbor seals which are 

particularly sensitive during the pupping season. Important seal haul out location exist in 

Corkscrew Slough (Bair Island), Calaveras Point and Mowry Slough. To mitigate these impacts, 

there will be restrictions during breeding periods to accessing tidal marsh and slough with known 

sensitive species. Boat access to Corkscrew Slough, Calaveras Point and Mowry Slough will be 

limited to the center channel during the harbor seal pupping season, March 15-June 15 to prevent 

flushing of pups from their mothers. Mechanized vehicles will only be allowed on levees and 
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existing roads unless approved by the Refuge Manager.

The use of larvicides and pupacides for the purpose of mosquito management are not likely to 

directly affect native mammal populations of the Refuge (USEPA 1998). Adverse effects on 

mammals from B.t.i., methoprene, and monomolecular films are not expected (Appendix K of the 

CCP) when applied according to the label instructions. Extensive acute toxicity studies indicated 

that B.t.i. is virtually innocuous to mammals (Siegel and Shadduck 1992). These studies exposed a 

variety of mammalian species to B.t.i. at moderate to high doses and no pathological symptoms, 

disease, or mortality were observed. Methoprene is not considered toxic to mammals (Appendix 

K of the CCP). Impacts to the mammalian community as a result of reduced invertebrate 

populations are not expected because many small mammal species that inhabit wetlands of the 

Refuge are herbivorous (invertebrates are not a primary component of their diet). Insectivorous 

species such as shrews (e.g., Sorex ornatus) occur in wetlands of the Refuge, and reduced 

arthropod populations may impact food availability for these species. Impacts to fish-eating 

harbor seals could occur if population-level effects to fish occur through the use of adulticides 

directly in waters and slough channels (see the following section on Fish). 

Oral exposure of pyrethrins could occur through consumption of plants or plant parts that have 

been sprayed (ground-based application). A terrestrial exposure model showed no acute or 

chronic risks to mammal or bird species (USEPA 2006). To reduce overall impacts of mosquito 

pesticides to non-target wildlife, mosquito pesticides will be applied according to pesticide label 

instructions and per habitat type. Application of larvicides and pupacides will be discouraged 

during high tide events in order to avoid impacts to tidal marsh species. The MADs will also be 

required to minimize the use of pesticides and continually investigate formulations and compounds 

that are least damaging to fish and wildlife (including invertebrate) populations.

Conversely, significant mosquito production and absence of mosquito control may negatively 

affect mammal populations. Although mosquitoes themselves are a part of estuarine ecosystems, 

they are known vectors of disease, including diseases that cause harm to humans and wildlife (e.g., 

WNV). Mammals known to be infected by WNV include horses, bats, chipmunks, skunks, rabbits, 

and squirrels.

Impacts to birds that use the Refuge may occur during access for mosquito monitoring, 

surveillance and control, as well as the application of pesticides. There are three federally listed 

bird species that inhabit the Refuge: the CLRA, the western snowy plover, and the California 

least tern. These species are covered in the subsequent section on effects to Threatened and 

Endangered Species. There are many other bird species listed as Species of Special Concern by 

the California Department of Fish and Game that occur on the Refuge.

Birds may be temporarily flushed as a result of ground access via foot or mechanized vehicle as 

well as aerial pesticide application, although birds will most likely return to roosting sites once 

operations have ceased in the area. It is anticipated that disturbance to most birds is likely to be 

low as a result of regular communication between the Refuge and the MADs on known nesting 

sites and other sensitive habitat locations, and limitations on marsh access in areas with nesting 

birds. However, repeated travel over the same areas creates paths through the marsh that 

increases access for predators. In order to reduce impacts, aerial mosquito control application will 

be encouraged over ground-based application methods.

Also, aerial mosquito control applications will avoid low level flight over water to access or exit the 
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Refuge as possible, thus minimizing bird disturbance. 

B.t.i. has practically no acute or chronic toxicity to birds (USEPA 1998, Appendix K of the CCP). 

There is the potential for B.t.i. to kill midge larvae (family Chironomidae). Chironomid (nonbiting midge) larvae can be abundant in wetlands and form a significant portion of the food base 

for other wildlife, including birds (Batzer et al. 1993; Cooper and Anderson 1996; Cox et al. 1998). 

As with B.t.i., there is concern regarding potential negative impacts to chironomid larvae from 

methoprene. Some studies have suggested methoprene impacts to other organisms that may form 

part of the food base for birds. McKenney and Celestial (1996) noted significant reductions in 

number of young produced in mysid shrimp at 2 ppb. Sub-lethal effects on the cladoceran, 

Daphnia magna, in the form of reduced fecundity, increased time to first brood, and reduced molt 

frequency have also been observed at lower concentrations of methoprene (Olmstead and LeBlanc 

2001). Methoprene showed no toxicity to slight toxic to birds at high concentrations and repeated 

exposure (Appendix K of the CCP, USEPA 2001). Monomolecular film is not known to cause 

direct chronic or acute avian toxicological effects to birds (Appendix K of the CCP). But 

monomolecular films are potentially lethal to any aquatic insect that lives on the water surface or 

requires periodic contact with the air-water interface to obtain oxygen (Appendix K of the CCP).

Pyrethrins are not considered toxic to birds (Milam et al. 2000, USEPA 2006) when applied at 

labeled rates. However, non-target effects to birds from pesticide application may occur as a 

result of reduced food base (e.g., Chironomid invertebrates). There is uncertainty with regard to 

pyrethrins, which have been shown to have no impact on large-bodied arthropods, but have been 

shown to reduce invertebrate populations, especially among small-bodied arthropods (Boyce et al. 

2007). 

 

Conversely, significant mosquito production and absence of mosquito control may negatively 

affect bird populations. Although mosquitoes themselves are a part of estuarine ecosystems, they 

are known vectors of disease, including diseases that cause harm to humans and wildlife (e.g., 

WNV). Mosquito-borne diseases such as WNV have shown to be lethal to wildlife. As of 2011, 326 

bird species have been listed in the Center for Disease Control WNV avian mortality database 

(http://www.cdc.gov/ncidod/dvbid/westnile/birdspecies.htm, accessed May 2, 2011). The list 

includes wildlife that inhabit tidal marsh such as waterfowl, grebes, heron, egrets, cormorants, 

songbirds (wrens, yellowthroats, song sparrows), and rails (clapper rail, Virginia rail, common 

moorhen, American coot).

Mosquito control pesticide may affects reptiles and amphibians through reductions in insects that 

serve as food source (Hoffman et al. 2008), and through direct individual effects from pesticide 

application or from trampling of individuals or habitat (e.g., access via ARGOs and ATVs). 

Methoprene, monomolecular films, and adulticides would not be permitted in vernal pool habitat. 

Only B.t.i. and B.s., which have no direct adverse effects to vertebrates will be permitted at Warm 

Springs. Refuge surveys over the last several years indicate that there is continued, long-term 

presence of VPTS and CTS in these pools. Truck use by mosquito abatement district staff would 

be restricted to established levees, roads, and berms and would not be permitted around vernal 

pools. Only all-terrain vehicles will be permitted around vernal pools and no vehicles will be 

permitted to enter vernal pools. With regard to adulticides, direct chronic effects have been found 

for the San Francisco garter snake from application of labeled rates of permethrin (synthetic 

pyrethroid, Hoffman et al. 2008). While this species does not occur on the Refuge, these findings 

suggest other reptiles may incur direct chronic effects. 
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Monitoring and surveillance activities are not expected to adversely affect non-target invertebrate 

populations. Biological and chemical treatment of mosquito populations on the Refuge has the 

potential to adversely affect non-target invertebrates and these are described below.

How reductions in certain invertebrate populations as a result of repeated pesticide applications 

would impact specific invertebrate-plant interactions (e.g., pollination) within tidal marsh and 

vernal pools of the Refuge are not known. However, because most pollinators do not have an 

aquatic lifecycle stage, it is likely that pollinators would not be affected by larvicide and pupacide 

application. Pollinators may be affected by adulticides which are broadcast in liquid form at ultralow volume, but use of adulticides would only be used under extreme conditions and in limited 

areas.

The effect on local populations of invertebrate species over time with periodic and continued use of 

B.t.i. is inconclusive, but potential for negative effects is a possibility (Appendix K of the CCP). 

Host range and effect on non-target organisms indicates that B.t.i. is relatively specific to the 

Nematocera suborder of Diptera, in particular filter-feed mosquitoes (Culicidae) and blackflies 

(Simuliidae) (Glare and O’Callaghan 1998). B.t.i. is pathogenic to some species of midges 

(Chironomidae) and Tipulidae, although to a lesser extent than mosquitoes and biting flies and is 

not reported to affect a large number of other invertebrate species (Glare and O’Callaghan 1998). 

B.t.i. concentration is may be important with regard to effects on nontarget organisms. Of 

particular concern is the potential for B.t.i. to kill midge larvae (family Chironomidae). 

Chironomid (non-biting midge) larvae are often the most abundant aquatic insect in wetland 

environments and form a significant portion of the food base for other wildlife (Batzer et al. 1993; 

Cooper and Anderson 1996; Cox et al. 1998). Reduced invertebrate populations as a result of food 

web effects (e.g., reduction of nematoceran, Diptera) have been shown in studies of B.t.i. (Hershey 

et al. 1998). However, current surveys indicate abundance of aquatic invertebrates in vernal pools 

receiving mosquito control with B.t.i. and B.s. (I. Loredo, pers. comm.). See the following section 

on endangered species for more information on VPTS.

 

Because methoprene is a juvenile hormone (JH) mimic and all insects produce JH, there is 

concern about potential adverse effects on non-target aquatic insects when this pesticide is used 

for mosquito control (Appendix K of the CCP). As with B.t.i., there is concern regarding potential 

negative effects on chironomid larvae due to their importance in food webs. As with any pesticide, 

toxicity is a factor of dose plus exposure. At mosquito control application rates, methoprene is 

present in the water at very small concentrations (4-10 parts per billion, initially). With regard to

exposure, chironomid larvae occur primarily in the benthos, either within the sediments and/or 

within cases constructed of silk and detritus. Thus, there may be differences with regard to 

exposure to methoprene between chironomid and mosquito larvae, the latter occurring primarily 

in the water column. The published literature on the effects of methoprene to chironomids is not 

as extensive as that for B.t.i. However, there is evidence for potential toxicity to chironomid and 

other aquatic invertebrates from methoprene treatments. In summary, there is evidence for 

significant adverse non-target effects from methoprene even when applied at mosquito control 

rates. 

Monomolecular films (Agnique, GB-1111) are potentially lethal to any aquatic insect that lives on 

the water surface and requires periodic contact with the air-water interface to obtain oxygen 

(USFWS 2004). The film interferes with larval orientation at the air-water interface and/or 
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increases wetting tracheal structures, thus suffocating the organism. As the film spreads over the 

water surface, the treatment tends to concentrate the larvae, which may increase mortality from 

crowding stress (Dale and Hulsman 1990).

All adulticides are very highly toxic to aquatic invertebrates in low concentrations (e.g., 1 ppb) 

(Milam et al. 2000). Because of this toxicity, pyrethrins can only be applied when there is high risk 

of mosquito-borne disease. Pyrethrins are known to cause acute toxicological effects to benthic 

invertebrates at rates used for mosquito abatement (USEPA 2006). Because pyrethrins are 

broad-spectrum insecticides, they are potentially lethal to most insects, including both terrestrial 

and benthic forms. There are also risks to aquatic invertebrates from direct deposition and runoff 

of the pesticides. To reduce impacts to aquatic invertebrates, adulticides will only be permitted in 

upland areas and interior water bodies. They will be applied only during low tides and away from 

open water and navigable slough channels to avoid potential runoff of the pesticides. 

Public access opportunities in all proposed alternatives could result in some disturbance and 

mortality to wildlife. Wildlife observation (through biking, boating, and walking), photography, 

environmental education, interpretation, and non-wildlife dependent recreation could result in 

temporary disturbance to wildlife while hunting and fishing will result in direct mortality of 

individual waterfowl and fish. However, these activities will be limited in several ways, including

habitat, time of day, and take limits. Signage will continue to be used to deter the public from 

entering closed areas to protect sensitive habitats. 

Hunting

Hunting would occur in all the alternatives, resulting in disturbing, injuring, and killing waterfowl. 

Waterfowl hunting on the ponds, open bay, and navigable sloughs will result in the direct loss of 

waterfowl, migratory species protected under the Migratory Bird Treaty Act. Exact hunt 

statistics are unknown because there are no hunter check-in stations. While the existing hunter 

harvest reporting is mandatory under the Hunting Special Use Permit, voluntary reporting of 

hunt harvest is not always followed by the hunters. It is estimated that there are over 2,000 

hunter visits annually that use the 7,500 acres of hunt area within the Refuge. Hunting on the 

Refuge requires the purchase of a Duck Stamp, is regulated by the State, and is not expected to 

result in population level effects to waterfowl species. Law enforcement monitoring is also used to 

control over-harvest.

Direct effects of hunting include mortality, wounding, and disturbance (DeLong 2002). Hunting 

can alter behavior (i.e., foraging time), population structure, and distribution patterns of wildlife 

(Owens 1977; Raveling 1979; White-Robinson 1982; Thomas 1983; Madsen 1985; Bartelt 1987; Cole 

and Knight 1990). There also appears to be an inverse relationship between the numbers of birds 

using an area and hunting intensity (DeLong 2002). In Connecticut, lesser scaup were observed to 

forage less in areas that were heavily hunted (Cronan 1957). In California, the numbers of 

northern pintails on Sacramento Refuge non-hunt areas increased after the first week of hunting 

and remained high until the season was over in early January (Heitmeyer and Raveling 1988). 

Following the close of hunting season, ducks generally increased their use of the hunt area; 

however, use was lower than before the hunting season began. Human disturbance associated 

with hunting includes loud noises and rapid movements, such as those produced by shotguns and 

boats powered by outboard motors. This disturbance, especially when repeated over a period of 

time, compels waterfowl to change food habits, feed only at night, lose weight, or desert feeding 

areas (Wolder 1993; Madsen 1995).
B-62

These impacts can be reduced by the presence of adjacent sanctuary areas where hunting does 

not occur and birds can feed and rest relatively undisturbed. Sanctuaries or non-hunt areas have 

been identified as the most common solution to disturbance problems caused from hunting 

(Havera et al. 1992). Prolonged and extensive disturbances may cause large numbers of waterfowl 

to leave disturbed areas and migrate elsewhere (Paulus 1984; Madsen 1995). In Denmark, 

hunting disturbance effects were experimentally tested by establishing two sanctuaries (Madsen 

1995). Over a five-year period, these sanctuaries became two of the most important staging areas 

for coastal waterfowl. Numbers of dabbling ducks and geese increased 4 to 20 fold within the

sanctuary (Madsen 1995). Thus, sanctuary and non-hunt areas are very important to minimize 

disturbance to waterfowl populations and ensure their continued use of the Refuge.

Intermittent hunting can be a means of minimizing disturbance, especially if rest periods in

between hunting events are weeks rather than days (Fox and Madsen 1997). It is common for

refuges to manage hunt programs with non-hunt days. At Sacramento Refuge, 3 to 16 percent of

pintails were located on hunted units during non-hunt days, but were almost entirely absent in

those same units on hunt days (Wolder 1993). In addition, northern pintails, American wigeon, 

and northern shovelers decreased time spent feeding on days when hunting occurred on public

shooting areas, as compared to non-hunt days (Heitmeyer and Raveling 1988). The intermittent

hunting program of three hunt days per week at Sacramento Refuge results in lower pintail

densities on hunt areas during non-hunt days than non-hunt areas (Wolder 1993). The Refuge 

also only allows hunting three days per week during the hunt season. However, intermittent 

hunting may not always greatly reduce hunting impacts.

The California Department of Fish and Game (CDFG) is California’s lead agency for management 

of fish, wildlife, and native plants— collectively called “wildlife.” CDFG has trustee responsibility 

for the conservation and management of wildlife for the benefit and enjoyment of the public.

Resident game species are protected on refuges by both Federal and State laws and regulations to

ensure that harvest rates do not negatively affect populations. The potential impacts of hunting 

on migratory bird and resident upland game birds are discussed and evaluated in the California

Environmental Quality Act process (California Department of Fish and Game 2001, 2004a). This

process results in periodically updated and publicly reviewed documents. Based on the findings of

these documents, the State ensures that game animal hunting in California does not adversely

impact its wildlife populations at an unacceptable level (California Department of Fish and Game

2004b).

Wildlife populations on the Refuge are able to sustain hunting and support other wildlifedependent priority uses. To manage the populations to support hunting, the Refuge adopts 

harvest regulations set by the State within Federal framework guidelines. The regulatory

procedures that govern harvest are described in the following section.

By its very nature, hunting has very few positive effects on the target species while the activity is

occurring. However, in the Service’s experience, hunting has given many people a deeper

appreciation of wildlife and a better understanding of the importance of conserving their habitat,

which has ultimately contributed to the Refuge System’s mission. Furthermore, despite the

potential impacts of hunting, a goal of the Refuge is to provide visitors of all ages an opportunity

to enjoy wildlife-dependent recreation. Of key concern is to offer a safe and quality program and
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ensure adverse impacts remain at an acceptable level.

Recreational hunting will remove individual animals, but does not negatively affect wildlife

populations. To assure that populations are sustainable, the California Fish and Game

Commission, in consultation with the CDFG, annually review the population censuses to establish

season lengths and harvest levels.

Harvest Management – Regulatory Procedures

Waterfowl populations throughout the United States are managed through an administrative

process known as flyways, of which there are four (Pacific, Central, Mississippi, and Atlantic). 

The review of the policies, processes, and procedures for waterfowl hunting are covered in the

following documents.

NEPA considerations by the Service for hunted migratory game bird species are addressed by

the programmatic document, “Final Supplemental Environmental Impact Statement: Issuance of

Annual Regulations Permitting the Sport Hunting of Migratory Birds (FSES 88–14),” filed with

the Environmental Protection Agency on June 9, 1988. The Service published a Notice of

Availability in the Federal Register on June 16, 1988 (53 FR 22582) and the Record of Decision on

August 18, 1988 (53 FR 31341). Annual NEPA considerations for waterfowl hunting frameworks

are covered under a separate EA and FONSI. Further, in a notice published in the September 8,

2005, Federal Register (70 FR 53776); the Service announced its intent to develop a new

Supplemental EIS for the migratory bird hunting program. Public scoping meetings were held in

the spring of 2006, as announced in a March 9, 2006, Federal Register notice (71 FR 12216).

Because the Migratory Bird Treaty Act stipulates that all hunting seasons for migratory game

birds are closed unless specifically opened by the Secretary of the Interior, the Service annually

promulgates regulations (50 CFR Part 20) establishing the Migratory Bird Hunting Frameworks. 

The frameworks are essentially permissive in that hunting of migratory birds would not be

permitted without them. Thus, in effect, Federal annual regulations both allow and limit the

hunting of migratory birds.

The Migratory Bird Hunting Frameworks provide season dates, bag limits, and other options for

the States to select that should result in the level of harvest determined to be appropriate, based

upon Service-prepared annual biological assessments detailing the status of migratory game bird

populations. In North America, the process for establishing waterfowl hunting regulations is

conducted annually. In the United States, the process involves a number of scheduled meetings

(Flyway Study Committees, Flyway Councils, Service Regulations Committee, etc.,) in which

information regarding the status of waterfowl populations and their habitats is presented to

individuals within the agencies responsible for setting hunting regulations. In addition, public

hearings are held and the proposed regulations are published in the Federal Register to allow

public comment.

For waterfowl, these annual assessments include the Breeding Population and Habitat Survey,

which is conducted throughout portions of the United States and Canada, and is used to establish

a Waterfowl Population Status Report annually. In addition, the number of waterfowl hunters 

and resulting harvest are closely monitored through both the Harvest Information Program 

(HIP) and Parts Survey (Wing Bee). Since 1995, such information has been used to support the 

adaptive harvest management (AHM) process for setting duck-hunting regulations. Under AHM, 
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a number of decision-making protocols render the choice (package) of pre-determined regulations

(appropriate levels of harvest) which comprise the framework offered to the States that year. 

California’s Fish and Game Commission then selects season dates, bag limits, shooting hours, and

other options from the Pacific Flyway package. Their selections can be more restrictive, but

cannot be more liberal than AHM allows. Thus, the level of hunting opportunity afforded each

State increases or decreases each year in accordance with the annual status of waterfowl

populations.

Waterfowl – Flyway Analysis

The 2010 annual waterfowl harvest estimate for the Pacific Flyway is 3 million ducks, an increase 

from 2.8 million in 2009. This estimate represents almost 20 percent of the estimated total harvest 

for the U.S. of 14.9 million ducks harvested (Raftovich et al. 2011).

Waterfowl harvested in California are made up of wintering waterfowl (coming from breeding 

grounds to the north) and the resident breeding population. For comparison, the Mid-Winter 

Survey Index for 2010 estimated 4.6 million total ducks for the Flyway (Collins and Trost 2010). 

Breeding waterfowl estimates in 2009 for California were 511,000 ducks, down from 554,000 in 

2008 (USFWS 2009). These numbers serve to demonstrate the relative importance of these areas 

(especially California) in the Pacific Flyway for wintering waterfowl, rather than for waterfowl 

production as a breeding site. 

Waterfowl – Regional Analysis

Most recently available annual harvest estimates for California indicate that approximately 1.7 

million ducks have been harvested by 55,500 waterfowl hunters in 2010, up from 1.4 million ducks 

harvested by 51,300 waterfowl hunters in 2009 (Raftovich et al. 2011). However, this may not be 

reflective of the exact hunter participation as estimates are based on voluntary survey

participation. 

Breeding waterfowl estimates in 2009 for California were 511,000 ducks, down from 554,000 in 

2008 (USFWS 2009). Mallards generally comprise more than half of each year’s breeding 

population estimate. As mentioned previously, the 2010 Midwinter Waterfowl Survey index for 

California totals 3.2 million ducks, further illustrating the relative importance of California’s 

overall wintering waterfowl capacity within the Pacific Flyway (Collins and Trost 2010). 

Waterfowl – Local Analysis

Waterfowl harvest numbers are unknown on the Refuge because there are no hunter check-in 

stations and reporting harvest numbers from the open bay is voluntary. The Refuge permits 

7,500 acres of ponds, open bay, and navigable sloughs for waterfowl hunting. Refuge staff 

estimates that there are roughly 2,000 hunter visits annually on the Refuge given the difficulty of 

accessing hunt areas and the challenging tide conditions of two low tides per day. Any potential 

take from these hunter visits are still far below the Midwinter Waterfowl Surveys’ estimated 

98,989 ducks for the San Francisco Bay for 2010 (Collins and Trost 2010). 

The hunting of waterfowl in the United States is based upon a thorough regulatory process that

involves numerous sources of waterfowl population and harvest monitoring data. California 

hunter’s estimated harvest of approximately 1.7 million ducks is approximately 11 percent of the 

total U.S. harvest of 14.9 million and more than 50 percent of the Pacific Flyway’s 3.0 million 

harvest estimate (Raftovich et al. 2011). Refuge staff estimates that hunting on the Refuge likely 
B-65

represents a negligible amount of all the waterfowl harvests conducted in California. Based on 

this analysis, the Service has concluded that hunting associated with each of the alternatives will 

not have a significant impact on local, regional, or Pacific Flyway waterfowl populations.

Alternative A

Alternative A would have the same effects on wildlife as described under Common to All 

Alternatives. Although we would continue to coordinate annually with the local MADs, we would 

not implement a Mosquito Management Plan under this alternative. The use of pyrethrin 

pesticides (adulticides) on the Refuge has only been permitted under limited conditions and 

application of adulticides has been fairly infrequent. Under Alternative A, the use of adulticides 

would continue to be limited and if necessary would only be allowed in upland areas and interior 

waterbodies. They would be applied only during low tides and away from open water and 

navigable slough channels to avoid potential runoff.

Under this alternative, recreation activities such as hiking and dog walking may potentially 

disturb wildlife in the tidal marsh and upland areas adjacent to trails causing wildlife to 

temporarily or permanently flush from these areas. In addition, while dogs are required to be on 

leash, sometimes owners may not comply with that regulation. In these instances, unrestrained 

dogs may go off the trail, thus threatening other visitors directly or flushing wildlife.

Dog disturbance to tidal marshes and other wildlife habitat can result in range of wildlife 

responses. Lenth and Knight (2008) found that the presence of dogs correlated with altered

patterns of habitat utilization for mule deer, small mammals, prairie dogs, and bobcats. Small 

mammals, including squirrels (Sciurus spp.) and rabbits (Sylvilagus spp.), also exhibited reduced 

levels of activity within 50 meters of trails in areas that allowed dogs when compared with areas

without dogs (Lenth and Knight 2008). Though leash rules have been found in certain urban 

parks to have no effect in protecting local biodiversity (Forrest and St. Clair 2006), the enforced 

use of leashes could restrict dog activity to a narrower trail corridor and minimize dogs’ influence 

on wildlife (Lenth and Knight 2008). 

Alternatively, because dog walking and public access has been occurring on designated trails for 

several decades, wildlife in the vicinity could be habituated to such activities. Some literature 

suggests that if animals perceive an activity as spatially predictable and nonthreatening, they may 

habituate to that activity (Whittaker and Knight 1998). For example, humans approaching from a 

parking area (an area with consistent human use) elicited less of a response from mountain sheep 

than did humans approaching from over a ridge, where human use was sporadic (MacArthur et al. 

1982). Cooper et al. (2008) found that the alert distance of the eastern gray squirrel did not differ 

between the approach by a human alone and the approach by a human with a dog. Miller et al. 

(2001) found this same result for songbirds; however Miller found that presence of a dog resulted 

in greater influence on mule deer than just approach by a human.

Certain types of disturbances have occurred within or adjacent to some marsh areas for a long 

time and certain CLRA appear to have habituated or become tolerant of these disturbances, while 

others appear to habituate over time or are unable to habituate to these disturbances at all. On 

numerous occasions at the Corte Madera Ecological Preserve, CLRA have been observed seeking 

refuge from unrestrained dogs entering tidal marshes from adjacent levees with public access (J. 

Garcia, pers. comm. 1994).
B-66

These disturbances have occurred despite the presence of signs notifying users that they are 

entering sensitive wildlife species areas and that pets must be under restraint while in the 

preserve area. Similarly, along the Redwood Shores Peninsula in San Mateo County, fences and 

signs installed to prevent access into areas with endangered species habitat have been repeatedly 

vandalized and people continue to enter the prohibited areas beyond the fences and signs (Popper 

and Bennett 2005).

Alternative B

In addition to the effects described under Common to All Alternatives, Alternative B includes a 

variety of other activities that may affect wildlife. Baseline surveys on focal plant and wildlife 

species as well as the implementation of an avian predator management plan will be beneficial to 

wildlife. Burrowing owl survey with partners and on the Warm Springs sub-unit would improve 

our knowledge of this species of concern. Management of grassland at the Warm Spring sub-unit 

would also benefit burrowing owl productivity. A variety of avian species have been observed 

preying upon the federally threatened western snowy plover and the federally endangered 

California least tern. Existing predator management (focused on problem mammals) does not 

control problem avian species. Under this alternative, removal and deterrence of avian predators 

will be accomplished by various methods, including hazing, relocation, or lethal control. While 

selected individuals will be removed, predator management will not result in a population-level 

effect on any of these species. Increased predator management to control problem avian species 

is expected to result in increases in migratory bird breeding success, recruitment, and total 

population size. 

Under Alternative B we would also implement a Mosquito Management Plan, as appended to the 

CCP. The Mosquito Management Plan provides the Service and MADs with a decision support 

system for mosquito control activities that is consistent with Refuge purposes, the mission and 

goals of the Refuge System, Department of Interior, and Service policy, and minimizes public 

health and wildlife health risk from Refuge-produced or harbored mosquitoes. The Mosquito 

Management Plan generally formalizes our ongoing mosquito control activities. However, under 

the Mosquito Management Plan, before we would allow the application of adulticides the MADs 

would need to show that mosquitoes on the Refuge pose a high risk for mosquito-borne disease. 

Should those criteria be met, including review and approval of proposed adulticide, then 

application would take place as described under Alternative A.

Increased law enforcement and staff contact with the public will reduce public disturbance to 

wildlife. Additional ecological improvements and enhancements under this alternative to La 

Riviere Marsh, Mayhew’s Landing, and Munster subunits would also significantly improve the 

quality of habitat for tidal marsh species. Parts of these subunits currently have poor tidal 

circulation, which results in poor quality vegetation and low abundance of wildlife species. Species 

may be temporarily disturbed by restoration activities that may involve earth-moving equipment, 

foot traffic, heavy equipment, and vehicles. 

The implementation of a weed management plan will have overall benefits to wildlife. The impacts 

of weed control are described under Common to All Alternatives. Wildlife will be temporarily 

disturbed or displaced by the increase in weed control activities, but will benefit in the long-term 

with increased native vegetation. However, these impacts are expected to be outweighed by the 

creation of additional, quality breeding habitat. Under this alternative, the grazing program 

would be expanded to include a previously ungrazed area and an additional 444 acres would be 
B-67

added when the refuge takes over management of the Pacific Commons lands. Impacts to wildlife 

are not expected to differ from those described under the Common to All Alternatives section. 

The prescribed burn season would be extended from the current September 1 – October 15 to 

June 15 –October 15. There may be some additional impacts to nesting birds by including the 

summer months. However, burns will be conducted infrequently (no more than once every 3 

years on average) on weedy areas of 50 acres or less. This will minimize potential impacts and 

allow wildlife to utilize unburned habitat nearby. Burrowing owl surveys would be conducted 

prior to any prescribed burns during their nesting season (up to August 31). If owls are observed, 

impacts would be minimized by using firebreaks or relocating the burn unit to exclude their 

burrows.

Also, prioritization of remaining lands within the approved acquisition boundary and a more active 

role in acquiring these lands (from willing sellers) will be beneficial to wildlife, particularly those 

most vulnerable to habitat loss (e.g., tidal habitat) as a result of sea-level rise from climate change.

Coordination with the Service’s LCC and I&M efforts to address near-term and long-term climate 

change impacts under this alternative will have added benefit to wildlife. Through understanding 

climate change impacts to the Refuge habitats, staff will identify adaptive changes or acquisition 

needs that may be required to continue to support wildlife. The process will help staff identify 

which wildlife are most at risk for climate change effects and prioritize management actions to 

protect them. 

The addition of a visitor center complex, fishing platforms/boardwalks, bus stop at headquarters, 

boat launch, photography blind, geocache program, earth cache program, and other associated 

infrastructure will increase number of visitors to the Refuge. The footprint of these features is

not expected to impact wildlife habitat because they will be constructed in sparsely vegetated 

areas or other low quality wildlife habitat. To mitigate disturbance, public access areas will be 

designated where the least disturbance to wildlife would occur. Increased visitor use in the form 

of wildlife observation, fishing, photography, recreation, and environmental education will result 

in more traffic in habitat areas and may cause wildlife to temporarily flush from the area. 

However, messaging to visitors will also promote stewardship of habitat and wildlife. Additional 

signage and fencing will be installed as needed to deter the public from entering sensitive wildlife 

habitats. Increased law enforcement presence and staff training to inform the public will also 

reduce wildlife disturbance. These activities are not expected to result in a population-level effect 

on wildlife. Increased outreach through signage and interpretive panels/material will be used to 

deter disturbance to wildlife. 

Under Alternative B, the closure of Tidelands Trail beyond the bridge crossings at Newark 

Slough to dog walking could reduce disturbance to migratory birds and other wildlife in tidal 

marsh areas. Expanding the buffer area (e.g., slightly shifting the trail inland) along the trail 

between the Harrier Spur and Tidelands Spur trails may also reduce disturbance to the adjacent

tidal marsh area that is at the same elevation. This separation would create a larger buffer area 

between dogs on this short, but sensitive section of the trail (see Figure 2), while still 

accommodating a loop access. 

The expanded interpretation and environmental education programs will accommodate additional 

visitors to the Refuge which could increase wildlife disturbance. Wildlife may be temporarily 

flushed from roosting areas, but these programs will be located away from sensitive breeding 
B-68

habitats. Overall, programs will be beneficial to wildlife because of their stewardship message. 

Expanded environmental education opportunities such as the Wetland Round-up and the 

Restoration Education Program will outreach to a wider audience through Spanish-translated 

programs as well as improve habitat with nursery propagation and planting opportunities that will 

be beneficial to wildlife. Increased habitat restoration activities by volunteers are also expected to 

improve wildlife habitat.

Alternative C

Alternative C would include those activities and effects in Alternative B. In addition, there would 

be increased benefits and disturbances from activities prescribed in this alternative. Baseline 

surveys on focal plant and animal species every five years will provide better data on the status of 

Refuge species. 

Additional ecological enhancements at Faber-Laumeister and Munster sub-units would benefit 

wildlife by providing higher quality habitat. The boat launch site would improve law enforcement 

access and thus wildlife protection. Research on mudflat and shallow pond biofilm will benefit 

knowledge on shorebirds. Enhancement and restoration to marsh-upland ecotone along the 

Ravenswood and Alviso Pond levees will provide additional wildlife habitat, especially during high 

tide events for tidal marsh species. Contaminants monitoring with partners will increase Refuge 

knowledge and management of wildlife resources. Climate change assessments and monitoring 

will also benefit long-term needs (such as identifying additional habitat) for wildlife.

Increased visitor uses under this alternative may potentially increase wildlife disturbance. A bus 

stop at the EEC, a walking bridge from the bus stop at headquarters, and equipment (e.g., 

kayaks, bicycles) loan system will increase interface between the public and wildlife. The 

equipment loan system could especially result in increased wildlife disturbance. Equipment users 

would be unsupervised and could flush wildlife. To mitigate for these potential effects, users 

would be instructed on responsible wildlife watching. Additional interpretation events will also 

increase public interface with wildlife, but potential for disturbance and impacts to habitat are 

expected to be low because these are guided activities. Wildlife could be flushed from roosting 

areas temporarily, but the Refuge would be closed after sunset allowing wildlife resting periods 

from the public. The auto tour route is not expected to significantly affect wildlife. Visitors will 

stay in their vehicles on the tour route or will have established pull-out areas with signage 

indicating sensitive areas. 

The opening of an additional 340 acres to hunting could increase hunting pressure on wildlife. 

However, this is only an increase of five percent of area open to hunting and would not be 

sufficient to cause a significant increase in the number of waterfowl taken. 

The addition of another fishing day (catch and release only) may cause temporary disturbance to 

wildlife. This event will be directed by staff that would oversee the activity and limit potential 

impacts to wildlife. Improvements to the environmental education programs are not expected to

increase disturbance to wildlife. Additional students will be accommodated in the programs, but 

these programs will continue to take place in areas with the least sensitive wildlife habitat. Also, 

these programs will be supervised by staff, trained teachers, or trained volunteers which will 

decrease wildlife impacts. Additional expansion of the geocache and earth cache programs is not 

expected to impact wildlife. These sites will be located in areas away from sensitive wildlife 

habitats. 
B-69

Under this alternative, eliminating all dog walking on the Refuge would remove all potential 

disturbance of wildlife from dog walking activities. 

Fish and Marine Invertebrates

Common to All Alternatives 

Ongoing tidal restoration activities could result in entrapment of fish and marine invertebrates 

during low tide conditions. Mitigation elements that are employed include avoiding construction 

activities during migration periods and using water control structures such as culverts to prevent 

entrapment. Tidal restoration activities will result in open water habitat appropriate for fish and 

invertebrate until sedimentation begins to take place. In the long-term, sub-tidal habitat is 

expected to increase and result in a benefit to fish and marine invertebrate populations. 

Weed management and wildlife management activities are not expected to affect fish and marine 

species because they occur away from waterways. Further, only herbicides and pesticides 

approved for use in aquatic environments would be permitted. The Refuge would continue to 

periodically use Service-approved herbicides including: Round-up®, GlyproPlus, Aquamaster and 

Rodeo® (glyphosate), Garlon 4® (triclopyr), Habitat, Polaris (imazapyr), 

Milestone (aminopyralid) and Transline® (clopyralid) to control invasive plants on the Refuge. 

Triclopyr is low in toxicity when eaten by animals (NPIC 2002). Triclopyr is slightly to practically 

non-toxic to highly toxic to fish, depending on the fish species and the triclopyr formulation; 

practically non-toxic to moderately toxic to waterfleas, depending on the formulation; and 

practically non-toxic to highly toxic to several water insects, depending on the species (NPIC 

2002). 

Aminopyralid, the active ingredient in the herbicide Milestone®, is considered practically nontoxic to most invertebrates, practically non-toxic to the estuarine/marine mysids and slightly toxic 

to the estuarine/marine mollusks and both freshwater and saltwater fish (U.S. EPA/OPP-EFED 

2004 in SERA, 2007). Additionally, this herbicide is considered non-toxic to slightly toxic to 

aquatic insects, such as dragonflies and water bugs (WSDOT 2009). Based largely or completely 

on information for aminopyralid, bioconcentration potential for Milestone® Herbicide is low (Dow 

AgroSciences 2006). 

Imazapyr which can be found in the herbicides Habitat® and Polaris®, has a half-life in water of 

2-4 days due to rapid photodegradation by sunlight. Because of this rapid photodegeneration, 

water contamination by imazapyr is generally not of concern. Additionally, due to Imazapyr’s 

short half-life and low toxicity it is generally not considered a threat to most species of fish and 

aquatic invertebrates and has low potential for bioconcentration in aquatic organisms (Leson and 

Associates 2005). 

Mosquito control pesticides are also applied at rates much lower than label rates and thus are not 

expected to affect fish species. Mosquito monitoring and surveillance activities are not expected 

to adversely affect fish because these activities do not occur within open sub-tidal waters of the 

Refuge (e.g., sloughs, channels, open bay) and are not expected to adversely affect water quality 

(e.g., turbidity, dissolved oxygen). Negative effects on fish populations are not expected from 

proposed larvicides and pupacides (USEPA 1998, Appendix K of the CCP). B.t. is practically nontoxic to fish (Appendix K of the CCP). However, the application of adulticides has the potential to 

adversely affect fish populations (Gunasekara 2005). Pyrethroids are considered highly toxic to 
B-70

fish and invertebrates (Appendix K of the CCP). In order to mitigate for any potential impacts to 

fish and marine invertebrates, any pesticide application would only occur during low tides to avoid 

impacts to species that may move into the tidal marsh plain during high tides.

Fish mortality occurs from fishing activities that are permitted in the open bay and other 

approved fishing locations of the Refuge. However, fishing is enforced by the CDFG regulations 

and is not expected to result in a population-level effect on fish species. 

Alternative A

Alternative A would have the same effects on fish and marine invertebrates as described under 

Common to All Alternatives. The use of adulticides for mosquito control can have adverse effects 

on fish. However, the frequency of conditions that would require use of adulticides on the Refuge 

has been rare over the past few decades. This pattern suggests that future use of adulticides in 

discrete areas of the Refuge is unlikely, but if occurred, the frequency and scope of application is 

not likely to cause significant adverse effects to fish and invertebrate populations. To reduce 

impacts to fish, adulticides will only be permitted in upland areas and interior water bodies. They 

will be applied away from open water and navigable slough channels to reduce impacts to fish. 

Application would only occur during low tides to avoid potential impacts to fish that may move into 

the tidal marsh plain during higher high or extreme tides.

Alternatives B and C

Under Alternatives B and C, future proposed tidal and managed marsh enhancements or 

restorations could result in impacts described for tidal restoration activities in Common to All 

Alternatives. Under both of these alternatives we would also implement a Mosquito Management 

Plan (Appendix K). Under the Mosquito Management Plan, the condition for use of adulticide 

would require a number of criteria including the presence of a mosquito-borne disease on the 

Refuge or within flight range of vector mosquito species present on the Refuge, as stated in the 

mosquito management plan. Should adulticides be necessary, the same restrictions on application 

described in Alternative A would apply. Species may be temporarily affected by restoration 

activities that may involve breaches and dredging, resulting in increased turbidity and 

sedimentation. However, these restoration and enhancement activities are expected to improve 

habitat in the long-term. Increased weed management activities are not expected to impact fish 

and invertebrates as they will take place away from navigable sloughs, channels, and the open bay. 

Additional fishing will be available at Coyote Creek Lagoon, Faber-Laumeister, and potentially 

Alviso Slough. Direct impacts include a probable higher fish loss than Alternative A. However, 

fishing will continue to adhere to state regulations and is not expected to adversely affect fish 

populations.

Endangered Species

Common to All Alternatives

All alternatives would result in short-term disturbance from operation and maintenance activities, 

but long-term benefits to listed species due to surveying and monitoring. Use of herbicides, 

prescribed burns, mechanical removal, cultural methods (e.g., salinization), and hand-pulling of 

non-native plants under all the alternatives have the potential to impact wildlife. Grazing results 

in trampling of vernal pools and their vegetation, but helps to increase vernal pool depths, 

increase aquatic diversity, and remove non-native grasses (Marty 2005). Removing non-native 

grasses will lengthen vernal pool inundation times, which will support the aquatic life stage of the 

VPTS and the CTS. Non-native, annual grasses produce heightened levels of plant biomass along 
B-71

vernal pool edges, which decreases the net amount of water available for native species by 

increasing evapotranspiration rates and resulting in an overall reduction in pool inundation period 

(Bremer et al. 2001, Frank 2003). Robins and Vollmar (2001), in a comprehensive review of 

grazing in vernal pool habitats, concluded that CCG populations thrived in regularly grazed or 

mowed sites and that ungrazed sites generally had smaller populations. Grazing exclosures at 

Warm Springs have also clearly demonstrated that within a single pool, CCG cover is higher in the 

grazed plot versus the ungrazed, fenced in plot (USFWS 2011). Water troughs are available in 

each pasture in the upland habitat to ensure that cows do not use the vernal pools as a water 

source and to therefore minimize effects to CCG and other vernal pool plants.

Prescribed burns would occur when VPTS are in the dry cyst stage. Most CTS are estivating in 

burrows at this time. Burns will be limited to areas 50 acres or smaller and will average no more 

than once every three years. Prescribed burns would also result in reduced air quality and 

visibility for wildlife. Short-term impacts of plant removal are likely to include disturbance of 

roosting (non-breeding) clapper rails or mice within close proximity to the field crews conducting 

the removal. Such disturbance may force wildlife to relocate to other parts of the Refuge 

temporarily. The effects of herbicide application to endangered species area the same as those 

discussed previously in the Wildlife and Fish sections. Herbicide use would primarily take place 

outside of endangered species habitat. There may be targeted manual or chemical control of small 

patches of invasive plants that take place in the edges of endangered species habitat, in order to 

prevent further spread of plants into the interior of endangered species habitat. In order to 

reduce impacts to endangered species, these activities will be conducted by a qualified biologist

and activities will not occur in the known presence of endangered species (e.g., identification of 

California clapper rail calls). 

All the alternatives include native plant restoration. Increasing native plant cover as well as 

improving the high marsh and ecotone/transition zones will provide additional habitat and refugia 

for listed tidal marsh species in high tide events.

The mammalian predator management will result in loss of red fox, feral cat, rat, skunk, and 

raccoon individuals. Other species may be taken as new data on predation becomes available. 

However, predator management will not result in a population-level effect on any of these species. 

Predator management activities may also indirectly disturb other wildlife. Installation of predator 

barriers may impede access for non-target species entering or exiting their feeding, roosting, and 

breeding areas. Trapping activities may also flush or disturb non-target wildlife. However, these 

activities are expected to be temporary and/or minimal in nature. Moreover, predator 

management activities are expected to result in increases in SMHM, CLRA, western snowy 

plover, and California least tern breeding success, recruitment, and total population size. 

Individual wildlife may be affected ongoing restoration projects, but restoration activities in all 

the alternatives are expected to benefit the long-term population of tidal marsh species, including 

listed species such as the CLRA and the SMHM. There could be a temporary loss of tidal marsh 

habitat from inundated areas where breaching occurs. Restoration activities could disturb and 

flush CLRAs and salt marsh harvest mice from the area. In the long-term, additional tidal marsh 

habitat would off-set the temporary loss of habitat. Mitigation measures adopted as part of the 

ongoing restoration projects to reduce impact to individuals includes surveying for presence or 

absence of individuals; providing a buffer near nest locations; avoiding activities during the 

nesting season; trapping and transplanting mice to other sites; installing barrier fence to prevent 
B-72

re-entry; and slow flooding to allow mammals to seek refugia in higher elevation vegetation. 

Mosquito Management

Because mosquito control (B.t.i., B.s.) is applied directly to vernal pools, VPTS may be directly 

affected. However, these biological controls are not expected to affect aquatic invertebrates such 

as VPTS (Appendix K of the CCP). Other pesticides, such as methoprene, monomolecular films, 

and adulticides will not be allowed for use in the vernal pools. Refuge surveys over the last 

several years indicate that there is continued, long-term presence of VPTS in these pools. In 

order to reduce impacts to listed species in vernal pool areas, MAD staff would be required to 

receive training in order to access vernal pool areas.

CTS could be adversely affected by mosquito monitoring, surveillance, or control due to crushing 

from access on foot or by mechanized vehicles. However, soil properties at Warm Springs are 

such that burrow crushing has not been observed; either by cattle, foot traffic, or ATV use 

(Loredo, 2012 personal communication). In any case, truck use would be restricted to established 

levees, roads, and berms and would not be permitted around vernal pools. Only all-terrain 

vehicles will be permitted around vernal pools and no vehicles will be permitted to enter vernal 

pools. Use of larvicides may have an indirect adverse effect on the CTS by reducing the 

availability of invertebrate prey. However, B.t.i. and B.s. are very target specific biological 

controls and the vernal pools at Warm Springs support an abundance and diversity of aquatic 

invertebrates that are not susceptible to these pesticides, most commonly ostracods, copepods, 

cladocera, coleoptera, and hemiptera. CTSs could also be adversely affected as described under 

the wildlife section. In order to reduce impacts to listed species in vernal pool areas, MAD staff 

would be required to receive training in order to access vernal pool areas.

Impacts to the steelhead and the North American green sturgeon are the same as those listed 

previously in the fish section. It is not anticipated that larvicides and pupacides will impact these 

fish species. In order to mitigate for any potential impacts to green sturgeon, any pesticide 

application would only occur during low tides to avoid impacts to species that may move into the 

tidal marsh plain during high tides. 

Mosquito monitoring, surveillance, or control could adversely affect CLRA. Walking and 

especially ATV or ARGO driving in the marsh has the potential to disturb CLRAs as well as crush 

nests, eggs, or chicks. Also, repeated travel over the same areas creates paths though the marsh 

that increases access for predators. In order to reduce impacts to CLRA from disturbance, access 

along tidal channels and sloughs will be restricted in order to reduce impacts to vegetation used as 

habitat by wildlife (e.g., nesting and escape habitat). Access (via foot or mechanized vehicle) to 

tidal marsh and muted tidal marsh for the purpose of mosquito management will not be allowed 

access February 1 to July 15 in areas that are inhabited by California clapper rails and along 

slough and channel edges (100-meter buffer).

Like other birds, as described previously in the wildlife section, mosquito control pesticides are 

not likely to have direct affects to CLRAs. Instead, CLRAs may be impacted indirectly by 

reduced invertebrate prey base as a result of adulticiding. However, this is a rarely used 

pesticide. It is not known what affect the frequent use of larvicides and pupacides in tidal marsh 

habitat would have on the invertebrate prey base of CLRAs.

The California least tern forages in sloughs and large channels within the areas affected by this 
B-73

plan. However, they are more often found foraging in the Bay or in managed ponds, and are not 

likely to be adversely affected by mosquito monitoring, surveillance, or control if best 

management practices are followed (e.g., avoiding nesting areas). If population-level impacts to 

forage fish occur, then California least terns could be negatively impacted (See wildlife section).

Western snowy plovers may occasionally forage in areas affected by this mosquito management. 

However, they do not nest in areas affected by this plan, and are more likely to forage on mudflats 

or along tidal channels at low tide. Therefore they are not likely to be adversely affected by 

mosquito monitoring, surveillance, or control if the best management practices are followed. As a 

precaution, access (via foot or mechanized vehicle) to seasonal pond habitats for the purpose of 

mosquito management would not be allowed between March 1 and September 15 in areas used by 

nesting western snowy plovers. If population-level impacts to invertebrate prey occur, then 

western snowy plovers could be negatively impacted (See wildlife section).

Adverse impacts to SMHM and other wetland mammals may occur as a result of marsh access via 

foot or mechanized vehicles for mosquito management activities. According to observations, 

vehicle effects on habitat include compacted soil, destroyed vegetation, and documented the 

destruction of at least one SMHM nest (Bias and Morrison 1993). In addition, repeated vehicle 

travel over the same areas creates paths through the pickleweed that increases access for 

predators. Lastly, they reported that vehicle travel can disrupt daily activity (e.g. movements) 

and has the potential to cause mortality of individual SMHM. In order to mitigate for any 

potential impacts from vehicles, mechanized vehicles will only be allowed on levees and existing 

roads unless approved by the Refuge Manager. Habitat enhancement and restoration activities 

for mosquito management may flush SMHM from their habitat. In order to mitigate for any 

potential impacts from habitat enhancement and restoration, marsh vegetation is to be hand 

mowed and removed down to the bare ground before dredging occurs to prevent harm to the 

SMHM. Areas of marsh vegetation that are submerged in water do not need to be mowed before 

dredging occurs. Before excavation occurs, crews must walk ahead of the equipment and haze 

SMHM out of vegetation. When clearing vegetation from an area, mowing will begin from the 

center of the area to be cleared and work toward the edges to avoid trapping SMHM in remaining 

patches of vegetation.

Impacts to the federally endangered CCGs are the same as those listed in the vegetation section. 

CCGs generally begin to bloom in April, and can be trampled and crushed by mechanized vehicles. 

During the germination and blooming period for CCG (which coincides with pond drying in the 

spring), ATVs will not be allowed around CCG pools and pools would be treated on foot. Foot 

access by trained personnel would not have a significant impact on goldfields. A map of CCG 

pools will be provided to mosquito abatement district staff and they would receive training to 

minimize impacts to areas with CCG blooms. In general, by the time CCG is germinating, pools 

are drying down significantly. Peak bloom generally occurs when the pond is completely dry. 

Most pollinators do not have an aquatic lifecycle stage, making it unlikely that pollinators would 

be affected by larvicide application. 

In order to reduce effects for mosquito management activities on endangered species, MADs 

would be required to attend Refuge-approved training on measures to avoid impacts to wetland 

wildlife and in identification of sensitive species. Also, aerial pesticide (larvicide or pupacide) 

application would be required in lieu of ground-based application methods in areas with 

endangered species.
B-74

All alternatives may have short-term minor disturbance on wildlife from visitor services 

opportunities. Generally however, listed species habitat is off limits to visitors. Also public 

education (through staff training and contact), law enforcement, and signage would help to

alleviate visitor disturbance. 

Alternative A

Alternative A would have the same effects on endangered species as described under Common to 

All Alternatives. As described in the section on fish, the frequency of conditions that would 

require use of adulticides on the Refuge has been rare (last application was in 2006 at Outer Bair 

Island), suggesting that future use of adulticides in discrete areas of the Refuge is unlikely, but if 

occurred, the frequency and scope of application is not likely to cause significant adverse effects to 

fish and invertebrate populations. To reduce impacts to steelhead and green sturgeon, adulticides 

will only be permitted in upland areas and interior water bodies. They will be applied away from 

open water and navigable slough channels to reduce impacts to fish. Application would only occur 

during low tides to avoid potential impacts to fish that may move into the tidal marsh plain during 

higher high or extreme tides.

Under Alternative A, recreation activities such as hiking and dog walking in designated areas of 

the Refuge have the potential to disturb endangered species such as the CLRA and SMHM. 

However, the degree of disturbance from these activities is unknown, though this activity has been 

going on for several decades. Although there are no recent CLRA or SMHM surveys in the area, 

staff believe there is presence of CLRA and SMHM is this area. It is suspected that CLRA and 

SMHM in the area may have become habituated to dog walking activities due to the length of time 

this activity has occurred. Some literature suggests that if animals perceive an activity as 

spatially predictable and nonthreatening, they may habituate to that activity (Whittaker and 

Knight 1998). For example, humans approaching from a parking area (an area with consistent 

human use) elicited less of a response from mountain sheep than did humans approaching from 

over a ridge, where human use was sporadic (MacArthur et al. 1982). Cooper et al. 2008 found 

that the alert distance of the eastern gray squirrel did not differ between the approach by a 

human alone and the approach by a human with a dog. Miller et al. 2001 found this same result for 

songbirds; however Miller found that presence of a dog resulted in greater influence on mule deer 

than just approach by a human.

While certain types of disturbances have occurred within or adjacent to some marsh areas for a 

long time and certain CLRA appear to have habituated or become tolerant of disturbances, others 

appear to habituate over time or are unable to habituate to disturbances at all. For example, 

certain CLRA in the Palo Alto Baylands Nature Preserve appear to be somewhat tolerant of the 

relatively common pedestrian traffic on the public boardwalk that dissects the marsh. CLRA 

nests have been documented within 10 feet of 16 trails in the Elsie Romer and Cogswell marshes 

in Alameda County and within 65 feet of a busy street near White Slough (Solano County). 

Alternatively, on numerous occasions at the Corte Madera Ecological Preserve, rails have been 

observed seeking refuge from unrestrained dogs entering tidal marshes from adjacent levees with 

public access (J. Garcia, pers. comm. 1994). While some of these studies have limited applicability 

to controlled dog walking, they do suggest a range of either a tolerance for disturbance or a 

potential for disturbance.
B-75

These disturbances have occurred despite the presence of signs notifying users that they are 

entering sensitive wildlife species areas and that pets must be under restraint while in the 

preserve area. Similarly, along the Redwood Shores Peninsula in San Mateo County, fences and 

signs installed to prevent access into areas with endangered species habitat have been repeatedly 

vandalized and people continue to enter the prohibited areas beyond the fences and signs (Popper 

and Bennett 2005).

CLRA reaction to disturbance may vary with season, however both breeding and nonbreeding 

seasons are critical times. Disturbance during the nonbreeding season may primarily affect 

survival of adult and subadult rails. Adult clapper rail mortality is greatest during the winter 

(Albertson 1995; Eddleman 1989), and primarily due to predation (Albertson 1995).

Human-related disturbance of CLRA in the winter, particularly during high tide and storm 

events, may increase the birds’ vulnerability to predators. The presence of people and their pets 

in the high marsh plain or near upland areas during winter high tides may prevent rails from 

leaving the lower marsh plain (Evens and Page 1983). CLRA that remain in the marsh plain 

during inundation are vulnerable to predation due to minimal vegetative cover available (Evens 

and Page 1986). A population viability analysis under development for CLRA identifies changes 

in adult survivorship as causing the greatest change in the population growth rate (M. Johnson, 

pers. comm.). Another model also indicates that adult survivorship of CLRA is the primary 

demographic variable for maintaining a stable population or causing the population to either 

increase or decline (Foin et al. 1997). These models indicate that survival of adult birds has the 

strongest effect on the perpetuation or extinction of the overall population.

Alternatives B and C

Under both alternatives, there will be increased temporary disturbance to listed species from 

survey activities, but no mortality is expected. Under Alternative B, Refuge staff will conduct 

additional surveys using standardized monitoring protocols for listed species. These changes in 

methodology will improve understanding of listed species and their recovery needs. Also under 

Alternative B, additional surveys will be conducted to determine presence of listed plants, 

including Suisun thistle, salt marsh bird’s beak, soft bird’s beak, and California sea-blite; there is 

no historical or current information on the presence of these species on the Refuge even though 

the Refuge provides potential habitat. Under Alternative C, additional research and Refuge-wide 

monitoring will further inform SMHM recovery needs. Under both of these alternatives we would 

also implement a mosquito management plan (Appendix K). The condition for use of adulticide 

would require a number of criteria including the presence of a mosquito-borne disease on the 

Refuge or within flight range of vector mosquito species present on the Refuge, as stated in the 

mosquito management plan. Should application of adulticides be necessary we would implement 

the same precautions as described in Alternative A.

Additional habitat enhancements and restorations under both alternatives will result in shortterm disturbance (e.g., flushing), but result in long-term benefits such as higher quality habitat for 

listed species. Listed species will especially benefit from ecological enhancements at La Riviere 

Marsh, New Chicago Marsh, and Faber-Laumeister where present. Wildlife may be temporarily 

flushed from habitat due to moving of dirt or breaching levees. Mitigation measures may include 

live-trapping and removing salt marsh harvest mice as well as fencing construction areas to 

prevent mice from re-entering the work area. Enhancing vernal pool/upland grassland habitat 

under both alternatives will benefit the VPTS and the CTS. The activities will cumulatively 
B-76

support the goals of the Refuge and the region in restoring and conserving wildlife resources.

Under Alternative B, the creation of nesting and roosting islands as feasible in the Alviso, Mowry, 

and Newark ponds will have a long-term benefit to the recovery of the western snowy plover and 

California least tern in ponds. However, these species may incur short-term disturbance from the 

construction of these islands. Birds may be temporarily flushed due to the operation of heavy 

equipment and foot traffic, making them vulnerable to predation. Construction activity will only 

take place during the non-breeding season and during the daytime, allowing birds a resting period 

at night. Further investigations on mudflat and shallow pond biofilm in Alternative C will inform 

management of ponds to improve shorebird diet, including snowy plovers and least terns.

Under both alternatives, implementation of the updated mammalian and an avian predator 

management plan will also help in the recovery of listed species by protecting population levels 

from predation. A variety of avian species have been observed preying upon the federally 

threatened western snowy plover and the federally endangered California least tern. Existing 

predator management (focused on problem mammals) does not control problem avian species. 

Under this alternative, removal and deterrence of avian predators will be accomplished by various 

methods, including hazing, relocation, or lethal control. While selected individuals will be 

removed, predator management will not result in a population-level effect on any of these species. 

Increased predator management to control problem avian species is expected to result in 

increases in SMHM, CLRA, western snowy plover, and California least tern breeding success, 

recruitment, and total population size. 

Under Alternative B, reduced dog walking access on the Tidelands trails would reduce the 

potential disturbance to endangered species such as the CLRA, by limiting dog walking to only 

the upland portion of the trails. Expanding the buffer area (e.g., slightly shifting the trail inland) 

along the trail between the Harrier Spur and Tidelands Spur trails may also reduce disturbance to 

the adjacent tidal marsh area that is at the same elevation. This separation would create a larger 

buffer area between dogs on this short, but sensitive section of the trail (see Figure 2), while still 

accommodating a loop access. 

Climate change actions under all alternatives will have added benefit to wildlife. Through climate 

change modeling and monitoring, staff will identify habitat changes and identify adaptive changes 

or acquisition needs that may be required to support wildlife. Modeling will help staff identify 

which species are most at risk of climate change effects and prioritize management actions to 

protect them. 

In Alternative C, the salt marsh harvest and the CLRA will benefit from the possible 

reintroduction into appropriate habitat and additional partnered research efforts. Additional 

studies on pepperweed effects on the SMHM will also be beneficial to understanding how to 

enhance their habitat. Heightening and expanding high marsh and ecotone/transition zone will 

also benefit listed tidal marsh species. Survey efforts for endangered and threatened plant 

species will benefit from management and knowledge of these resources.

In both alternatives, prioritization of remaining lands within the approved acquisition boundary 

and a more active role in acquiring these lands (from willing sellers) will be beneficial to 

endangered species, particularly those most vulnerable to habitat loss (e.g., tidal habitat) as a 

result of sea-level rise from climate change.
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Increased visitor activities in both alternatives may result in increased disturbance to listed 

species. Improved access to the Faber-Laumeister, improvements to trails, additional wildlife 

viewing facilities, launch sites for canoe and kayak, installation of a photography blind, 

photography permit system, additional fishing facilities, additional vernal pool tours, and a remote 

camera system in Alternative B may result in more visitors and increased disturbance to 

endangered species. Added wildlife observation opportunities are likely to increase contact 

between visitors and wildlife, causing wildlife to temporarily flush. Further public amenities in 

Alternative C such as interpretive signage, kayak/canoe rental, a Water Trail stop, boat dock, and 

photography blinds will further increase wildlife and visitor interface. However, these activities 

generally will not take place in listed species habitat. Also, more public education (through staff 

training and contact), law enforcement, and signage would complement the increased visitation. 

Further, signage and fencing will be installed to protect sensitive habitat as needed. 

Under Alternative C, the prohibition of dog-walking on all areas of the Refuge, would result in 

further protection of endangered species habitat, particularly for the CLRA and the SMHM. 

Social and Economic Environment

None of the alternatives are expected to adversely affect the social and economic environment of

Alameda, Santa Clara, and San Mateo Counties. Tourism revenue is potentially generated 

through a variety of activities held at the Refuge, such as guided walks and special events. If an 

increase in visits to the Refuge occurs or there is a net increase in visitors to the area, this could 

benefit the local economy and employment if visitors utilize local businesses such as gas stations, 

markets, and restaurants. However, increased visitation can lead to more traffic in the local area 

as well. Increased visitation also provides an opportunity for public education, which can foster 

stewardship for these native habitats.

Recreation

Alternative A

Current wildlife-dependent recreational opportunities at the Refuge include wildlife observation, 

photography, hunting, and fishing. In addition, some non-wildlife dependent opportunities such as 

jogging, dog-walking, and bicycling are also allowed at certain Refuge locations. There are 

currently more than 30 miles of trails with multiple access sites and overlooks to facilitate wildlife 

observation. Guided photography and interpretive walks are offered, as well as hosting on-site 

special events for National Wildlife Refuge Week, Earth Day, the South Bay Bird Festival, and 

others. The Refuge has a visitor contact station in Fremont from that provides limited visitor 

contact services. These recreational opportunities provide some social benefits to nearby 

communities by providing access to open space. Dog walking is a primary outdoor activity for the 

surrounding communities; for a significant portion of the population, it may represent the only 

time during the week that they are outdoors and in nature. Dog walking would also provide an 

opportunity for this non-traditional user groups to become stewards of the Refuge. 

Hunting and fishing are allowed in the open bay waters and navigable sloughs. Shoreline and pier 

fishing are also offered at the Refuge. Hunting is allowed on 7,500 acres of Refuge land in areas 

that do not conflict with wildlife observation or photography. 

Alternatives B and C

Under Alternatives B and C, there would be increased recreation opportunities and interpretation
B-78

programs. In addition to those elements described in Alternative A, Alternative B would provide 

more refuge support to hunters through additional hunt meetings, an interactive Web site, and 

hunting materials. Recreational fishing would also be enhanced through updated brochures and 

wayside exhibits. Fishing would be improved at Coyote Creek Lagoon and Faber-Laumeister

with a small fishing platform, and possibly introduced at Alviso Slough. The headquarters fishing 

pier would also be updated to improve the fishing experience there. Additionally, water-based, 

wildlife-dependent opportunities would be enhanced. Visitors will benefit from the creation of a 

launch site and kayak tours where feasible on the Refuge. The creation of a bus stop at 

headquarters will facilitate access to the Refuge and encourage recreation. Under Alternative B, 

reduced trail access for dog walkers (less 0.8 miles, or a loss of 38 percent) would result in reduced 

recreation opportunities for this user group. Conversely, reduced dog walking access could 

improve other visitors’ experience. While dogs are required to be on leash at the Refuge, 

sometimes owners may not comply with that regulation. In these instances, unrestrained dogs 

may impact other visitors’ enjoyment of the refuge resources. Unrestrained dogs may go off the 

trail flushing wildlife thus diminishing wildlife observation opportunities. Dogs on leash and off 

leash may become a threat to other visitors. Lack of physical safety, whether real or perceived, 

could impact visitors’ enjoyment of refuge resources.

Under Alternative C, recreation would be enhanced through increased interpretive events such as 

vernal pool tours, an additional fishing day event, installation of a boat dock, development of a stop 

along the Water Trail, installation of additional photography blinds, a youth photography camp, 

opening of an additional 340 areas to hunting, installation of a universally accessible hunt blind, 

additional hunting classes/orientation, and equipment (e.g., kayak, canoe, bicycle) rental. The 

creation of bus stop at the EEC will facilitate access to the Refuge and encourage recreation. 

Construction of a walking path from the bus stop to the Refuge headquarters will also facilitate 

access. Also under this alternative, the prohibition of dog walking on all Refuge trails would result 

in no opportunity for this non-traditional user group, or for this group to become aware of Refuge 

purposes.

Both alternatives would also considerably expand or enhance environmental education 

opportunities for the local community. More children and adults will be accommodated through 

the programs. Programs will also be expanded to include Spanish and other languages as feasible. 

Economy

An analysis on the economic impact of the alternatives to the local region (the three counties 

where the Refuge is located) was done by the Policy Analysis & Science Assistance Branch of the 

U.S. Geological Survey, Fort Collins, Colorado. The full report is listed as Appendix A. The 

methods are described as follows.

Economic input-output models are commonly used to determine how economic sectors will and 

will not be affected by demographic, economic, and policy changes. The economic impacts of the 

management alternatives for the Refuge were estimated using IMPLAN (Impact Analysis for 

Planning), a regional input-output modeling system developed by the USDA Forest Service. 

IMPLAN is a computerized database and modeling system that provides a regional input-output 

analysis of economic activity in terms of 10 industrial groups involving more than four hundred 

economic sectors (Olson and Lindall 1999). The IMPLAN model draws upon data collected by the 

Minnesota IMPLAN Group from multiple Federal and State sources, including the Bureau of 

Economic Analysis, Bureau of Labor Statistics, and the U.S. Census Bureau (Olson and Lindall 
B-79

1999). The year 2009 IMPLAN data profiles for Alameda, San Mateo, and Santa Clara were used 

in this analysis. The IMPLAN county level employment data estimates were found to be 

comparable to the U.S. Department of Commerce, Bureau of Economic Analysis, Regional 

Economic Information System data for the year 2009. 

Because of the way industries interact in an economy, activity in one industry affects activity 

levels in several other industries. For example, if more visitors come to an area, local businesses 

will purchase extra labor and supplies to meet the increase in demand for additional services. The 

income and employment resulting from visitor purchases from local businesses represent the 

direct effects of visitor spending within the economy. Direct effects measure the net amount of 

spending that stays in the local economy after the first round of spending; the amount that doesn’t 

stay in the local economy is termed a leakage (Carver and Caudill 2007). In order to increase 

supplies to local businesses and meet increased demand, input suppliers must also increase their 

purchases of inputs from other industries. The income and employment resulting from these 

secondary purchases by input suppliers are the indirect effects of visitor spending within the 

economy. Employees of the directly affected businesses and input suppliers use their incomes to 

purchase goods and services. The resulting increased economic activity from new employee 

income is the induced effect of visitor spending. The indirect and induced effects are known as the 

secondary effects of visitor spending. “Multipliers” (or “Response Coefficients”) capture the size 

of the secondary effects, usually as a ratio of total effects to direct effects (Stynes 1998). The sums 

of the direct and secondary effects describe the total economic impact of visitor spending in the 

local economy. 

For each alternative, regional economic effects from the IMPLAN model are reported for the 

following categories: 

• Employment represents the change in the number of jobs generated in the region from a 

change in regional output. IMPLAN estimates for employment include both full time and 

part time workers, which are measured in total jobs.

• Labor Income includes employee wages and salaries, including income of sole proprietors 

and payroll benefits. 

• Value Added measures contribution to Gross Domestic Product. Value added is equal to

the difference between the amount an industry sells a product for and the production cost 

of the product, and is thus net of intermediate sales. 

In terms of the CCP, there are several factors that affect the local economy: 

• Increased visitors as a result of additional public use opportunities offered on the Refuge, 

which would result in increases in local spending.

• Increased spending in the local economy as a result of more staff needed to implement 

CCP actions.

• Increased work-related expenditures (e.g., contracts, materials) as a result implementing 

the CCP actions.

Table 3 shows the estimated percent of non-local Refuge visits and visitor days under each 

alternative. 
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Table 3. Estimated Annual Refuge Visitation by Visitor Activity for Alternatives A, B, and C

Visitor Activity

Total 

number of 

visits

Percentage of 

non-local 

visits (%)

Total number 

of non-local 

visits

Number 

of hours 

spent at 

Refuge

Number of 

non-local 

visitor 

daysa

Alternative A

Fishing 3,700 10% 370 4 185

Waterfowl hunting 3,900 10% 390 6 293

Nature trails/other wildlife observation 746,341 10% 74,634 2 18,659

Total Visitation 753,941 75,394 19,137

Alternative B

Fishing 4,070 10% 407 4 204

Waterfowl hunting 3,900 10% 390 6 293

Nature trails/other wildlife observation 970,243 10% 97,024 2 24,256

Total Visitation 978,213 97,821 24,753

Alternative C

Fishing 4,070 10% 407 4 204

Waterfowl hunting 4,095 10% 410 6 307

Nature trails/other wildlife observation 1,044,877 10% 104,488 2 26,122

Total Visitation 1,053,042 105,305 26,633

a

One visitor day = 8 hours.

Alternative A

Table 4 summarizes the direct and total economic impacts in the three-county area of Refuge 

management activities for Alternative A. Under Alternative A, the Refuge management activities 

directly related to Refuge operations generate an estimated 17 jobs, $850,100 in labor income, and 

$1.42 million in value added in the local economy. Including direct, indirect, and induced effects, 

all the Refuge activities generate a total economic impact of 30 jobs, $1.62 million in labor income, 

and $2.77 million in value added. In 2009, total labor income was estimated at $190 billion and 

total employment was estimated at 2.42 million jobs for the local three-county area (IMPLAN 

2009 data). Thus, total economic impacts associated with the Refuge operations under Alternative 

A represent less than one hundredth of one percent of total income (0.0008 percent) and total 

employment (0.001 percent) in the overall three-county area economy. Total economic effects of 

Refuge operations play a much larger role in the communities near the Refuge where most of the 

Refuge-related expenditures and public use-related economic activity occurs. 
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Table 4. Economic Impacts of the Refuge Management Activities for Alternative A

Employment Labor 

Income Value Added

(# full & part time jobs) ($ thousands) ($ thousands) 

Refuge administrationa

Direct effects 3.1 $234.6 $395.4

Total effects 9.2 $594.7 $1,035.4

Public use activities

Direct effects 13.4 $615.5 $1,027.7

Total effects 21.0 $1,022.1 $1,729.7

Aggregate impacts 

Direct effects 16.5 $850.1 $1,423.1

Total effects 30.2 $1,616.8 $2,765.1 a

Staff salary purchases and work-related purchases.

Alternative B

Table 5 summarizes the direct and total economic impacts in the three-county area of Refuge 

management activities for Alternative B. Under Alternative B, the Refuge management activities 

directly related to Refuge operations would generate an estimated 22 jobs, $1.14 million in labor 

income, and $1.91 million in value added in the local economy. Including direct, indirect, and 

induced effects, Refuge activities would generate a total economic impact of 43 jobs, $2.34 million 

in labor income, and $4.02 million in value added. Total economic impacts associated with the 

Refuge operations under Alternative B represent less than one hundredth of one percent of total 

income (0.001 percent) and total employment (0.002 percent) in the overall three-county area 

economy. Total economic effects of Refuge operations play a much larger role in the communities 

near the Refuge where most of the Refuge-related expenditures and public use-related economic 

activity occurs.

Table 5. Economic Impacts of the Refuge Management Activities for Alternative B

Employment Labor 

Income Value Added

(# full & part time jobs) ($ thousands) ($ thousands) 

Refuge administrationa 

Direct effects 4.6 $344.1 $579.9

Total effects 16.2 $1020.4 $1786.1

Public use activities

Direct effects 17.3 $795.3 $1,328.0

Total effects 27.2 $1,320.9 $2,235.4

Aggregate impacts

Direct effects 21.9 $1,139.4 $1,907.9

Total effects 43.4 $2,341.4 $4,021.6 a

Staff salary purchases and work-related purchases.
B-82

Alternative C

Table 6 summarizes the direct and total economic impacts in the three-county area of Refuge 

management activities for Alternative C. Under Alternative C, the Refuge management activities 

directly related to Refuge operations would generate an estimated 27 jobs, $1.5 million in labor 

income, and $2.51 million in value added in the local economy. Including direct, indirect, and 

induced effects, all Refuge activities would generate a total economic impact of 53 jobs, $2.97 

million in labor income, and $5.1 million in value added. Total economic impacts associated with 

Refuge operations under Alternative C represent less than one hundredth of one percent of total 

income (0.002 percent) and total employment (0.002 percent) in the overall three-county area 

economy. Total economic effects of Refuge operations play a much larger role in the communities 

near the Refuge where most of the Refuge-related expenditures and public use-related economic 

activity occurs.

Table 6. Economic Impacts of the Refuge Management Activities for Alternative C

Employment Labor Income Value Added

(# full & part time 

jobs) ($ thousands) ($ thousands) 

Refuge administrationa

Direct effects 8.5 $640.0 $1,078.5

Total effects 23.8 $1,550.2 $2,694.1

Public use activities

Direct effects 18.7 $855.9 $1,429.1

Total effects 29.3 $1,421.5 $2,405.6

Aggregate impacts

Direct effects 27.2 $1,495.8 $2,507.6

Total effects 53.1 $2,971.6 $5,099.7 a

Staff salary purchases and work-related purchases.

Cultural Resources

Under Federal ownership, archaeological and historical resources within the Refuge receive 

protection under Federal laws mandating the management of cultural resources, including, but 

not limited to, the Archaeological Resources Protection Act; the Archaeological and Historic 

Preservation Act; the Native American Graves Protection and Repatriation Act; and the National 

Historic Preservation Act. There are some identified historic and cultural elements on the 

Refuge, but the Refuge has not been thoroughly surveyed. These known elements are protected 

from Refuge activities. However, the Refuge is located in an area which was once open water and 

marsh making it difficult to locate physical evidence of pre-historic human activity. Moreover, 

archaeological sites also tend to be situated on higher land than the Refuge (N. Valentine, pers. 

comm.). 

Alternative A

Tidal restoration activities could involve ditching, earthmoving, and breaching that could disturb 

or uncover unknown cultural resources. Invasive weed control activities, particularly mechanical 

(e.g., mowing, weed whacking, pulling) and cultural (e.g., grazing, burning) methods could also 

disturb and uncover unknown cultural resources. Any known cultural resource locations will be 

avoided. Measures to minimize impacts to cultural resources employed include pre-design/pre-
B-83

construction surveys and exploratory excavation by a qualified archaeologist as needed before 

undertaking major management activities. Activities may also be designed to avoid impacting 

identified or potential cultural resources.

To preserve Refuge historic resources, all undertakings, including, but not limited to, construction 

activities, will continue to comply with Section 106 of the National Historic Preservation Act of 

1966, as amended, as outlined in the existing Programmatic Agreement between the Service and 

the California State Historic Preservation Officer. Staff will also coordinate with the Service’s 

Regional Archaeologist to comply with Federal laws relating to cultural resources.

Alternatives B and C

Under Alternatives B and C, improving the ecological function at La Riviere Marsh, Mayhew’s 

Landing, New Chicago Marsh, Faber-Laumeister, and Munster sub-units of the Refuge could 

involve additional ditching, earthmoving, and breaching that could disturb or uncover unknown 

cultural resources. Invasive weed control activities, particularly mechanical (e.g., mowing, weed 

whacking, pulling) and cultural (e.g., grazing, burning) methods could also disturb and uncover 

unknown cultural resources. Marsh-upland ecotone restoration through planting of native 

vegetation at Faber-Laumeister, La Riviere, EEC, Pond A6, Pond A8, Ravenswood Ponds, and 

Alviso Ponds could also result in uncovering or disturbance of unknown cultural resources. Any 

known cultural resource locations will be avoided. Measures to minimize impacts to cultural 

resources may be employed, including pre-design/pre-construction surveys and exploratory 

excavation by a qualified archaeologist as needed before undertaking any of these actions. 

Activities may also be designed to avoid impacting identified or potential cultural resources.

To preserve Refuge historic resources, all undertakings under both alternatives, including, but not 

limited to, construction activities, will continue to comply with Section 106 of the National Historic 

Preservation Act of 1966, as amended, as outlined in the existing Programmatic Agreement 

between the Service and the California State Historic Preservation Officer. Staff will also 

coordinate with the Service’s Regional Archaeologist to comply with Federal laws relating to 

cultural resources.

Climate Change

Common to All Alternatives

In 2010, the U.S. Fish and Wildlife Service published Rising to the Challenge: A Strategic Plan 

for Responding to Accelerating Climate Change. This Strategic Plan charges comprehensive 

conservation planning to incorporate climate change into its planning and decision making. 

Climate change could have a profound effect on the Refuge because most of the area is below sealevel. Sea-level rise as a consequence of climate change could reduce the total land area of the 

Refuge. Based on a continuous record of mean sea level for the San Francisco Bay Estuary, the 

rate of relative sea level rise at the Presidio from 1855 to the present is estimated to be 0.12

centimeter per year (Moffatt and Nichol et al. 1988). Neglecting the unusual values associated 

with all El Niño events during the recent 19-year period from 1967 to 1985, sea-level rose at a rate 

of 0.18 centimeter per year, which still indicates that the rate of rise is increasing (Moffatt and 

Nichol et al. 1988). Climate change in conjunction with tidal wetland restoration and non-native

vegetation removal activities will result in an increase in wetland or open water habitat, and a 

decrease in upland habitat. However, much of the diked upland on the Refuge was historically 

tidal wetland.
B-84

A Sea-Level Affecting Marshes Model (SLAMM) was conducted in 2010 to assess habitat changes 

as a result of climate change on the Refuge (Clough and Larson 2010). The SLAMM identified 

habitat changes on the Refuge units that may be expected under five sea-level rise scenarios. The 

middle scenario of a one meter rise in sea level predicts losses in most tidal and upland habitat 

types (Table 7), but particularly great losses to irregularly flooded marshes. Increases would be 

in estuarine open water and salt marsh habitats (Clough and Larson 2010). However, there were 

a number of assumptions that were made in the creation of the SLAMM, suggesting the need to 

consider other modeling efforts to confirm these findings.

Table 7. Predicted Loss Rates of Land Categories by 2100 Given Simulated

Scenarios of Eustatic Sea Level Rise

SLR by 2100 (m) 0.39 0.69 1 1.5 2

Tidal Flat 17% 23% 30% 40% 45%

Brackish Marsh 19% 21% 39% 84% 94%

Inland Fresh Marsh 9% 10% 13% 21% 39%

Undev. Dry Land 12% 12% 13% 13% 14%

Inland Shore 10% 18% 44% 69% 82%

Source: Clough and Larson 2010.

Climate change could also result in changing habitat which would affect wildlife and plant 

communities. Not only could habitats shift, but also the timing of when birds migrate and leaves 

begin to bud (IPCC 2007). Climate change could magnify impacts on wildlife habitat, reduce 

native vegetation, and increase occurrence of non-native (plant and animal) species on the Refuge. 

Climate change can result in physiological changes, phenological (lifecycle) changes, range shifts, 

community changes, ecosystem process shifts, and multiple stressor conditions (Parmesan and 

Galbraith 2004). Climate change may require organisms to migrate at much higher rates than 

they have done in the recorded past (Malcolm and Pitelka 2000). Native plants may not thrive in 

the Refuge boundaries due to changing temperatures. Moreover, climate change could result in 

changes to local food web dynamics, altering prey resources in the bay waters adjacent to the 

Refuge. The potential changes to food availability near the Refuge could deter or attract wildlife, 

therefore affecting productivity.

Over time, climate change could result in significant ramifications for wildlife and vegetation. 

Tidally-influenced habitat for wildlife at the shoreline could disappear, forcing wildlife to move 

onto higher ground, possibly competing with other wildlife for habitat. Plant communities at the 

shore could be inundated or be forced to migrate to higher ground, competing with other 

vegetation (Smerling et al. 2005).

The U.S. Department of Interior issued an order in January 2001 requiring its land management

agencies to consider potential climate change impacts as part of long-range planning endeavors. 

The increase of carbon within the earth’s atmosphere has been linked to the gradual rise in

surface temperature, commonly referred to as global warming. In relation to comprehensive

conservation planning for national wildlife refuges, carbon sequestration constitutes the primary

climate-related impact to be considered in planning. The U.S. Department of Energy’s report

Carbon Sequestration Research and Development (1999) defines carbon sequestration as “...the

capture and secure storage of carbon that would otherwise be emitted to or remain in the
B-85

atmosphere.”

Terrestrial biomes of all sorts—grasslands, forests, wetlands, tundra, perpetual ice, and desert—

are effective in preventing carbon emissions and in acting as biological “sinks” for atmospheric 

carbon monoxide. The Department of Energy’s report conclusions note that ecosystem protection 

is important to carbon sequestration and may reduce or prevent loss of carbon currently stored in 

the terrestrial biosphere. Preserving natural habitat for wildlife is the heart of any long-range 

plan for national wildlife refuges. This in turn contributes positively to efforts to mitigate humaninduced global climate changes. Several impacts of climate change have been identified (Hassol 

2004) that may need to be considered in future project planning and addressed in the future:

• Habitat availability for cold water fish, such as trout and salmon in lakes and streams, 

could be reduced.

• Forests may change, with some species shifting their range northward or dying out and 

other trees moving in to take their place.

• Ducks and other waterfowl could lose breeding habitat due to stronger and more frequent 

droughts.

• Changes in the timing of migration and nesting could put some birds out of sync with the 

life cycles of their prey species.

Alternative A

Alternative A would have benefits against climate change because restoration and enhancement of 

tidal marsh would increase carbon sequestration. Public use and management operations (e.g., 

vehicle emissions, heavy equipment operation) would have a minor impact on climate change. To 

minimize greenhouse gas emissions that contribute to climate change, we will continue to make 

energy improvements at our facilities and upgrade the vehicle fleet with energy efficient vehicles 

whenever possible.

Alternative B

Under Alternative B, increased habitat restoration and reduced carbon footprint (e.g., hybrid 

transportation, solar technology, and energy efficiency) would result in a positive impact on 

reducing climate change. Coordination with the Service’s LCC and I&M programs on climate 

change information and projections will help inform habitat restoration planning and 

implementation, such as creating additional marsh and mudflat habitat in specific locations in light 

of bay area sea-level rise projections. Increased visitation would result in a negligible impact on 

increasing climate change effects. Additional visitor opportunities may result in visitors choosing 

the Refuge as their destination rather than another location offering similar opportunities in the 

Bay area. The Refuge is one of many locations in the Bay area for wildlife-dependent recreational 

opportunities. Also, if there are more visitors, a bus stop at headquarters will provide visitors 

with an alternative travel option with a lower carbon footprint. 

Alternative C

Under Alternative C, we would anticipate that further increases in habitat restoration, further 

reduced climate change impacts, and increased visitation would result in a negligible impact on 

climate change. In addition to a bus stop at headquarters, Alternative C would also include a bus 

stop at the EEC to encourage visitors to use public transit to lower their carbon footprint.
B-86

Environmental Justice

Executive Order 12898 (“Federal Actions to Address Environmental Justice in Minority 

Populations and Low-Income Populations”) requires all Federal agencies achieve environmental 

justice by “identifying and addressing, as appropriate, disproportionately high and adverse human 

health or environmental effects of its programs, policies, and activities on minority populations 

and low-income populations.” Environmental justice is defined as the “fair treatment for peoples 

of all races, cultures, and incomes, regarding the development of environmental laws, regulations, 

and policies.” 

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. The developing 

environmental justice strategy of the Service extends this mission by seeking to ensure that all 

segments of the human population have equal access to America’s fish and wildlife resources, as 

well as equal access to information that will enable them to meaningfully participate in activities 

and policy shaping.

No minority and low-income populations or communities would be disproportionately affected by 

any of the alternatives. Outreach and environmental education opportunities will be directed to 

encourage more participation by local minority and low-income populations. The Service has 

concluded that none of the alternatives would disproportionately affect any one population or 

community. 

Cumulative Effects

Cumulative effects are those effects on the environment resulting from incremental consequences 

of the Service’s proposed actions when added to other past, present, and reasonably foreseeable 

future actions, regardless of who undertakes those actions. Cumulative effects can be the result of 

individually minor impacts that can become significant when added over a period of time. It is 

difficult to accurately analyze cumulative effects because one action may increase or improve a 

resource in one area, while other unrelated actions may decrease or degrade that resource in 

another area. Moreover, CCP actions may be inhibited or accelerated by other activities or 

management plans occurring in the same area. This section assesses how these other activities in 

addition to the CCP actions would affect the physical, biological, cultural, and social and economic 

environment. 

Cumulative effects will take into account several ongoing projects where the Refuge is located. 

These projects are described in the CCP and include:

South Bay Salt Pond Restoration Project. The SBSPRP is the largest tidal wetland restoration 

project on the West Coast. When complete, the restoration will convert 15,100 acres of 

commercial salt ponds at the south end of San Francisco Bay to a mix of tidal marsh, mudflat, 

managed pond, open water, and other wetland habitats. The property was purchased by the State 

of California and the Service from Cargill Salt as part of a larger land transaction that included 

1,400 acres of salt crystallizer ponds on the east side of the Napa River. The acquisition of the 

South Bay salt ponds provides an opportunity for landscape-level wetlands restoration, improving 

the physical, chemical, and biological health of the San Francisco Bay. The goals of the SBSPRP 

are to restore and enhance a mix of wetland habitats, provide wildlife-oriented public access and 

recreation, and provide for flood management in the South Bay. 
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Initial Stewardship Plan. The Initial Stewardship Plan (ISP) was an interim plan to maintain 

and enhance the biological and physical conditions within the salt ponds acquired from Cargill in 

2003 in the interim period between the cessation of salt production and the implementation of the 

long-term restoration plan (the SBSPRP). The primary objectives of the ISP include: 

• cessation of salt concentrating processes within the ponds; 

• circulation of bay water through the ponds and tidally-restore the Island Ponds (Alviso 

Ponds A19, A20, and A21);

• maintain existing open water and wetland habitat for the benefit of wildlife, including 

habitat for migratory shorebirds and waterfowl and resident breeding species;

• maintain ponds in a restorable condition to facilitate future long-term restoration;

• meet all regulatory requirements, especially discharge requirements to maintain water 

quality standards in the South Bay;

• work within existing funding constraints; and 

• maintain existing levels of flood control

Shoreline Study. The Shoreline Study was originally authorized by Congress in 1976 to assess the 

need for flood protection in the South Bay. The results of the original Shoreline Study in 1992 

concluded that the Army Corps of Engineers could not economically justify developing a Federal 

flood management project in the South Bay in large part due to commercial salt pond levees that 

provided some level of flood protection within the Shoreline Study area. The acquisition and 

eventual restoration planning of 15,100 acres of salt ponds in the South Bay by the Federal and 

State government in 2003 affected the utilization of those pond levees as flood control structures. 

In 2002, the U.S. House of Representatives requested that the Corps review its previous 1992 

Shoreline Study, expanding the scope to include environmental restoration and protection, as well 

as tidal and fluvial flood damage reduction and related purposes. Initial reconnaissance analysis 

conducted by the Corps in 2004 determined that due to current and future anticipated conditions 

to the South Bay, a Federal flood control and ecosystem restoration project would be justified.

In 2005, the Corps, Santa Clara Valley Water District (SCVWD), and the Conservancy kicked off 

the first study phase of the South San Francisco Bay Shoreline Study and are now in the

preliminary stages of beginning environmental review. The project is currently undertaking 

“scoping” to determine the range of environmental issues to be addressed in the alternative 

development and analysis process.

San Francisco Estuary Invasive Spartina Project. The San Francisco Estuary Invasive Spartina 

Project was created in 2000 by the California State Coastal Conservancy to develop a regionally 

coordinated project to address the rapid spread of four introduced and highly invasive Spartina

(cordgrass) species in the San Francisco Estuary. The Spartina Control Program, the “action 

arm” of the Spartina Project, was created to arrest and reverse the spread of invasive, non-native 

cordgrass species in the Estuary to preserve and restore the ecological integrity of the Estuary’s 

intertidal habitats and estuarine ecosystem. The Project is currently working with the Control 

Program to develop a set of “best practices” for tidal marsh restoration to minimize the risk of 

spreading invasive Spartina and its hybrids.
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Eden Landing Ecological Reserve Restoration Project. The Eden Landing Ecological Reserve 

(ELER) Restoration Project was established in May 1996 to restore former salt ponds and 

crystallizers to tidal salt marsh and seasonal wetlands as well as provide public recreational 

access. In 1996, CDFG, working with the Wildlife Conservation Board (WCB), East Bay Regional 

Park District, California Wildlife Foundation, the cities of San Jose, Milpitas and Fremont, and 

Caltrans, acquired the Baumberg Tract from Cargill Salt Company at the ELER and began 

efforts to restore more than 830 acres of former salt ponds to vital habitat. In 2003, DFG acquired 

an additional 5,500 acres of former salt ponds for ELER as part of the SBSPRP acquisition that 

was accomplished with funding from WCB, USFWS, and four private foundations.

Today, CDFG is actively managing the 6,300 acres of former salt ponds at ELER as part of the 

SBSPRP and moving forward on its restoration to create a mix of tidal marsh and managed pond 

habitat. Restoring tidal action to thousands of acres of diked salt ponds throughout the South Bay 

is essential to bringing back the natural wetland habitat. In April 2004, DFG successfully created 

an extension of North Creek from the Old Alameda Creek channel. In 2006, North Creek was 

connected to restore more than 300 acres to tidal action and re-establish several miles of sloughs. 

The current project will complete the connection of Mt. Eden Creek and restore about 300 acres 

to tidal action and re-establish several miles of sloughs. Future restoration plans, including 

linking segments of the Bay Trail, are underway to link more ponds to tidal action and the Bay as 

part of the SBSPRP.

Alviso Slough Restoration Project. The SCVWD completed an EIR in November 2009 to assess 

the possible actions for restoring the Alviso Slough. The EIR recommended vegetation removal 

along the Slough of 3.7 acres with dredging to an 8-foot depth which would provide for two-way 

boat navigation. Since the 1940s, Alviso Slough has been subject to various changes due to 

subsidence, dredging activity, and dynamic interaction of the Slough and Bay. Over time, 

sediment has filled in areas of the Slough and the vegetation has grown and thrived, thereby 

reducing the extent of open water in the Slough. In 2004, the SCVWD began planning to control 

vegetation in the Slough, develop long-term plans for providing public access, maintain flood 

protection, reduce mosquito nuisance, and integrate planning with the SBSPRP.

Lower Guadalupe River Flood Protection Project. This flood protection project was constructed 

to prepare the channels to handle storm water runoff in the event of a 100-year flood, protect 

endangered species, preserve fish and migratory bird habitat, and allow for open-space recreation. 

Beginning in 2003, SCVWD made flood protection improvements along 6.5 miles of the Guadalupe 

River from the I-880 bridge north to the Union Pacific Railroad bridge in Alviso. 

San Francisquito Creek Restoration Project. The San Francisquito Creek Joint Powers 

Authority (SFCJPA) is a government agency formed in 1999 by the cities of Palo Alto, Menlo 

Park and East Palo Alto, and the SCVWD and San Mateo County Flood Control District. The 

SFCJPA implements projects that provide multiple communities flood protection, environmental, 

and recreational benefits, and it coordinates Creek maintenance and emergency preparedness and 

response communication. SFCJPA’s first major capital project is moving forward with an 

expedited design and environmental review process to provide increased flood protection for the 

East Palo Alto and Palo Alto communities along the flood-prone reach of San Francisquito Creek 

downstream (east) of U.S. Highway 101.
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The project is designed to improve stream flow from the downstream face of East Bayshore Road 

all the way to San Francisco Bay and reduce local flood risks during storm events, as well as 

provide the capacity needed for upstream flood protection projects being planned by the SFCJPA. 

It will also be designed to provide ecological enhancements for the endangered and other species 

that call this watershed home, and to allow for new and improved trails for residents and visitors 

along the Creek and near the Bay.

Increasing the Creek’s flow capacity from San Francisco Bay to 101 will be achieved by widening 

the Creek channel within the reach to convey peak flows for 100-year storm events; removing an 

abandoned levee-type structure to allow flood flows from the Creek channel into the Palo Alto 

Baylands Preserve north of the Creek; and constructing an outlet structure for Caltrans’ 

enlargement of the Highway 101/East Bayshore Road Bridge over San Francisquito Creek. At 

the time of this writing, the Project is currently in design phase.

Cumulative Effects on the Physical Environment

All the alternatives are anticipated to enhance or restore the natural physical environment of the 

Refuge to provide long-term benefits to native wildlife and vegetation. The projects mentioned 

above, such as the SBSPRP, will have the added benefit of providing additional habitat for native 

tidal marsh wildlife and vegetation. However, the Refuge is surrounded by a heavily urbanized 

area facing endless development pressures which could result in profound cumulative effects to 

the physical environment of the area. Any nearby developments (e.g., Cargill Redwood City 

Saltworks Plan), including residential or commercial projects, could have negative implications on 

the Refuge environment such as the introduction of invasive vegetation, nuisance wildlife, trash, 

and contaminants. Projects adjacent to the Refuge also increase human disturbance in the form 

of foot and vehicle traffic. The Refuge has little control over these external impacts, but has and 

will continue to work with partners during their planning process to protect and encourage the 

restoration of important native habitat.

Cumulative Effects on Biological Resources

All proposed alternatives would have long-term benefits for native wildlife species and habitats 

within the area. The alternatives integrate wildlife conservation activities with compatible 

wildlife-dependent opportunities that would represent a cumulative benefit for local wildlife, 

native plant communities, and human communities. 

The conversion of neighboring ponds to tidal marsh, as mentioned in the previous projects, could 

also result in a positive cumulative effect to biological resources. The SBSPRP will restore tidal 

marsh and other wetlands in the South Bay, providing additional habitat to wildlife resources. 

These former Cargill salt ponds will provide extensive habitat for endangered species, special 

status species, migratory waterfowl and shorebirds, and fish and other aquatic species. The 

project will incorporate a broad, upland transition zone where feasible and may make use of the 

expansive, compacted former salt ponds for use as seasonal wetlands habitat. This project, along 

with the objectives described in the CCP, will result in a positive net benefit to the ecosystem by 

restoring natural habitat for endangered species and migratory birds. Increased tidal wetlands 

restoration prescribed for both the CCP and SBSPRP will also provide additional fish and 

invertebrate habitat for nursery and foraging. Enhancing vernal pool/upland grassland habitat in 

the CCP will benefit the VPTS and the CTS. The activities will cumulatively support the goals of 

the Refuge and the region in restoring and conserving wildlife resources. 
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Because the Refuge is surrounded by urban development, development projects have the high 

likelihood of reducing the added biological benefits that habitat restoration projects previously 

described will provide. Development projects surrounding the Refuge will potentially result in 

additional disturbance to wildlife resources and negative impacts to native habitats. It is likely 

that additional restoration activities will be needed to offset future loss of open space to 

commercial and residential developments.

Visitor activities prescribed in the alternatives and other public access opportunities such as The

Bay Trail (administered by the Association of Bay Area Governments) and the San Francisco Bay 

Area Water Trail would result in increased visitation to the area in addition to those prescribed in 

the CCP. The increased visitor uses of hiking, bicycling, boating, guided tours, and environmental 

education programs combined would add more visits to the Refuge, which could result in 

increased disturbance to wildlife and degradation of habitat. This increased visitation would add 

to the total visitation to the area that is already being generated by the Bay Trail system. The 

Refuge will work with The Bay Trail and Water Trail staff as well other projects to mitigate any 

potential disturbance and avoid sensitive habitat areas on the Refuge. 

In California, 38 refuges provide over 450,000 acres of habitat for wildlife. Eighteen of these 

refuges, including Don Edwards San Francisco Bay NWR, allow waterfowl hunting. Hunting on 

Refuge lands as well as hunting on neighboring California Department of Fish and Game lands is 

an existing activity that took place prior to the Refuge’s establishment. The hunt season, type of 

waterfowl hunted, and hunt limits are regulated under State regulations. These regulations are 

designed to ensure that harvest does not reduce populations to unsustainable levels. Although 

hunting will result in direct loss of individuals, this activity is not expected to result in a 

population-level effect on any of the hunted species. Moreover, the amount of hunting on the

Refuge under any of the alternatives is not expected to substantially increase. Any additional 

lands open to hunting would be negligible. Hunting would be enhanced through more interaction 

with hunters, improvements to existing hunt blinds, and additional hunt materials.

Cumulatively, visitor activities could potentially increase disturbance to wildlife and damage 

habitat. Some activities will be guided or supervised such as interpretive and environmental 

education programs. There are more than 750,000 visits to the Refuge each year. Under the 

CCP, it is expected that the increase in visitor opportunities will increase visits by 33 percent over 

15 years. Because the Refuge already accommodates a large number of visitors, biological 

resources are not anticipated to be significantly affected by the increased visitation. Additional 

signage, closure of sensitive areas, and increased law enforcement would be required elements to 

provide prior to increased visitor access in order to prevent or reduce disturbance and 

degradation. Fencing as needed will be placed near sensitive sites to deter visitors from 

disturbing wildlife. Reduced or eliminated access for dog walking may result in reduced 

disturbance to habitat for wildlife in the Refuge area.

Cumulative Effects on Cultural Resources

In general, the Service adheres to the policies and regulations pertaining to the protection of 

cultural resources in order to avoid or mitigate for any significant adverse effects resulting from 

management activities. The actions in the CCP will continue to adhere to those policies and 

regulations. No adverse effects on cultural resources are anticipated from any of the alternatives

or other local activities. 
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Cumulative Effects on the Social and Economic Environment

Permitting mosquito management activities are expected to result in a positive benefit to public 

health by reducing the threat of mosquito-borne viruses. Other action alternatives, particularly 

those involving expansion of wildlife-dependent recreation, interpretation, and environmental 

education, would provide benefits to the residents of the bay area. In addition, the environmental 

education and outreach programs would attempt to reach a diverse audience. Additional 

recreational opportunities in the form of fishing locations, interpretive opportunities, a 

photography blind, and hunting outreach will act in concert with the Bay Trail and Water Trail 

systems. Reduced or eliminated access for dog walking may increase recreation pressure on 

nearby dog walking areas (e.g., Coyote Hills Regional Park).

Tourism dollars could be generated from the increased recreation opportunities. Local 

restaurants, stores, lodging, and gas stations could benefit under any of the alternatives. Contract 

work may benefit the local economy, particularly grazing and haying activities contracted to a 

local farmer or rancher. 

Table 8. Summary Impacts of Alternatives

No Action Alternative B:

Moderate increase in 

wildlife management, 

habitat management, 

visitor services, and 

environmental 

education programs

Alternative C:

Substantial increase in 

wildlife management, 

habitat management, 

visitor services, and 

environmental 

education

Physical Environment

Hydrology Changing hydrological 

patterns from tidal 

restoration projects and 

mosquito management

likely to result in shortterm erosion and 

sedimentation, but longterm improved tidal 

connectivity

Additional tidal 

restoration and 

enhancements resulting 

in additional 

hydrological benefits

Same as Alternative B

Water 

Quality/Contaminants

Tidal restoration 

projects likely to result 

in temporary increases 

in turbidity and potential 

release of embedded 

contaminants, but longterm benefits such as 

regular tidal exchange

Additional tidal 

restoration and habitat 

creation may result in 

temporary increases in 

turbidity as well as 

potential release of 

embedded contaminants

Same as Alternative B

Soils and Topography Erosion from tidal 

restoration activities, 

but with long-term 

sedimentation benefits

Increased erosion due to 

additional restoration 

and construction 

activities, but with longterm sedimentation 

benefits

Same as Alternative B

Air Quality/Climate Minor impacts from 

restoration activities

including temporary 

Increased minor impacts 

from additional 

restoration activities; 

Same as Alternative B
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localized dust and 

vehicle emissions

increased tailpipe 

emissions from 

increased visitors

Hazardous 

Materials/Safety

No adverse effects from 

continued use of 

herbicides and mosquito 

pesticides, all herbicides 

and pesticides must go 

through the Service

approval process

Same as Alternative A; 

positive benefit from 

increased law 

enforcement and 

informational signage

Same as Alternative B

Biological 

Environment

Vegetation Conversion of managed 

ponds and diked 

wetlands to tidal habitat; 

beneficial impact to 

native plant communities

Additional beneficial 

improvements to native 

plant communities; 

positive impact from 

tidal enhancements and 

restoration of ecotone; 

minor impact due to 

public use and 

environmental education 

activities

Same as Alternative B

Wildlife Minor loss of habitat for 

upland species; 

beneficial impacts to 

tidal marsh species; 

minor disturbance due to 

mosquito management 

activities; minor 

disturbance and 

waterfowl mortality 

from hunting

Same as Alternative A;

improved surveying and 

monitoring of species; 

increased weed control, 

habitat restoration, and 

enhancement will benefit 

wildlife; minor impact 

due to wildlife-oriented 

activities

Same as Alternative B; 

beneficial impacts from 

additional weed control, 

habitat restoration, and 

enhancements; minor 

impact due to public use 

and environmental 

education activities

Fish and Marine 

Invertebrates

Minor impact due to 

tidal restoration and 

mortality from fishing; 

no population-level effect 

on species; beneficial 

impact due to increased 

habitat restored

Same as Alternative A; 

increased fishing 

mortality but no 

population-level effect; 

beneficial impact from 

increased habitat 

restored

Same as Alternative B 

Endangered Species Beneficial impacts due to 

habitat restoration; 

minor disturbance due to 

mosquito management 

activities; minor 

disturbance due to 

habitat and tidal 

restoration

Same as Alternative A; 

improved inventory and 

monitoring of species, 

minor impact due to 

wildlife-oriented 

activities

Same as Alternative B

Social and Economic 

Environment

Recreation Beneficial impact due to 

recreational 

opportunities

Beneficial impact due to 

additional recreational 

opportunities

Same as Alternative B

Economy No negative effects Minor beneficial impact Same as Alternative B
B-93

identified due to increased staffing 

and contract needs, and 

increased visitation to 

area due to recreational 

activities

Climate Change Beneficial impact

through additional 

carbon sequestration 

through tidal marsh 

restoration; improved 

energy efficiency in 

facilities and vehicle 

fleet 

Beneficial impact

through further tidal 

marsh restoration, 

LEED certification of 

EEC and headquarters, 

and bus stops to 

facilitate public transit

Same as Alternative B

Cultural Resources Ground disturbing 

activities from tidal 

marsh restoration and 

enhancements may 

result in impacts to 

cultural resources

Same as Alternative A Same as Alternative A

Environmental Justice No impacts anticipated Same as Alternative A Same as Alternative A
B-94

Chapter 5. List of Planning Team Members and Persons Responsible for 

Preparing this Document

Eric Mruz Refuge Manager, Don Edwards San Francisco Bay NWR

Melisa Helton Wildlife Refuge Specialist, Don Edwards San Francisco Bay NWR

Winnie Chan Refuge Planner, San Francisco Bay NWR Complex

Jennifer Heroux Visitor Services Chief, San Francisco Bay NWR Complex

Cheryl Strong Wildlife Biologist, Don Edwards San Francisco Bay NWR

Ivette Loredo Wildlife Refuge Specialist, Don Edwards San Francisco Bay NWR

Rachel Tertes Wildlife Biologist, Don Edwards San Francisco Bay NWR
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Chapter 6. Coordination, Consultation, and Compliance

Agency Coordination and Public Involvement

The draft CCP and EA were prepared with the involvement of technical experts, community 

groups, and private citizens. The Service has invited and continues to encourage public 

participation through planning updates and public comment periods. 

Notice of Intent

A Notice of Intent to prepare a CCP and EA for Don Edwards San Francisco Bay NWR was 

published in the Federal Register on July 26, 2006. 

Environmental Review and Consultation

As a Federal agency, the Service must comply with provisions of NEPA. An EA was developed to 

evaluate reasonable alternatives that would meet stated goals and assess the possible 

environmental, social, and economic impacts on the human environment. This EA serves as the 

basis for determining whether implementation of the preferred alternative would result in a 

Federal action significantly affecting the quality of the environment. The EA also acts as a vehicle 

for consultation with other government agencies and interface with the public in the decisionmaking process.

Other Federal Laws, Regulations, and Executive Orders

In undertaking the preferred alternative, the Service would comply with the following Federal 

laws, Executive Orders (EOs), and legislative acts: Intergovernmental Review of Federal 

Programs (EO 12372); Archaeological Resources Protection Act of 1979, as amended; Fish and 

Wildlife Act of 1956; Fish and Wildlife Conservation Act of 1980 (16 USC 661-667e); Fish and 

Wildlife Improvement Act of 1978; Endangered Species Act of 1973 (16 USC 1531 et seq.); 

National Environmental Policy Act of 1969; Federal Noxious Weed Act of 1990; Floodplain 

Management (EO 11988); Protection of Wetlands (11990); National Historic Preservation Act of 

1966, as amended; National Wildlife Refuge System Improvement Act of 1997; Antiquities Act of 

1906; Protection and Enhancement of the Cultural Environment (EO 11593); Archaeological and 

Historic Preservation Act of 1974 (PL 93-291; 88 STAT 174; 16 USC 469); Environmental Justice 

(EO 12898); Management and General Public Use of the National Wildlife Refuge System (EO 

12996); Refuge Recreation Act of 1962, as amended; Invasive Species (EO 13112); Migratory Bird 

Treaty Act of 1918, as amended (MBTA); and Responsibilities of Federal Agencies to Protect 

Migratory Birds (EO 13186).

Distribution and Availability

The draft CCP and EA has been sent to various agencies, organizations, community groups, and 

individuals for review and comment. Copies of this EA are available from the Don Edwards San 

Francisco Bay NWR, 7715 Lakeville Highway, Petaluma, CA, 94954 (phone 707/769 4200), and 

San Francisco Bay National Wildlife Refuge Complex, 1 Marshlands Road, Fremont, CA, 94536 

(phone 510/792 0222).

 
B-96

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Appendix A. Regional Economic Impacts of Current and Proposed 

Management Alternatives for Don Edwards San Francisco 

Bay National Wildlife Refuge 

San Francisco National Wildlife Refuge

Description

The Don Edwards San Francisco Bay National Wildlife Refuge was established in 1972 to preserve and 

protect critical habitat and associated wildlife, to aid migratory waterfowl, and to provide an opportunity 

for wildlife-oriented recreation and nature study. The refuge currently encompasses 19,000 acres in San 

Mateo, Alameda, and Santa Clara counties at the southern end of San Francisco Bay in northern 

California. It is surrounded by an urban population of over 7 million people, making it the largest urban 

wildlife refuge in the world. The refuge has an extensive environmental education outreach, with a 

variety of programs geared toward school children, teacher education, and the general public. 

The refuge is comprised of a variety of habitats including mudflats, salt marshes, open water, and salt 

ponds. This range of habitat supports a large variety of wildlife including five endangered species. The 

refuge provides major habitat for the endangered California clapper rail and salt- marsh harvest mouse. 

San Francisco Bay is a key wintering area for diving ducks along the Pacific Flyway; the south bay is 

used primarily by scaup, surf scoters, and ruddy ducks. The south bay wetlands support hundreds of 

thousands of shorebirds along with the largest wading-bird rookery in San Francisco Bay. 

The refuge has a visitor center at its administrative headquarters in the city of Fremont, and an 

environmental education center in Alviso on the southeastern edge of the refuge. Boating is a popular 

activity on the Bay, and a number of launch facilities are adjacent to the refuge. Hiking trails are 

numerous throughout the refuge. Wildlife observation, fishing, and waterfowl hunting are popular 

activities. 

Area Economy

San Francisco NWR is located at the southern end of San Francisco Bay in northern California. Table 8-

16 shows the area economy. The area population increased by 5.6 percent from 1995 to 2005, compared 

with a 14.1 percent increase for the state of California and a 11.4 percent increase for the U.S. as a whole. 

Area employment increased by 7.7 percent from 1995 to 2005, with the state of California showing a 20.5 

percent increase and the U.S. a 17.0 percent increase. Area per capita income increased by 25.9 percent 

over the 1995-2005 period, while the state of California and the U.S. increased by 15.8 and 13.2 percent 

respectively. 
Table 8-16. San Francisco NWR:

Summary of Area Economy, 2005 

(Population & Employment in 000’s; Per Capita Income in 2006 dollars)

Population Employment Per Capita Income

County 2005 

Percent 

change 

1995-

2005 2005 

Percent 

change 

1995-2005 2005 

Percent 

change 

1995-2005 

Alameda CA 1,451.1 7.8% 896.0 12.8% $42,956 22.9% 

Santa Clara CA 1,705 7.9% 1,117.2 5.0% $51,112 22.0% 

San Mateo CA 701.2 3.2% 462.5 12.8% $59,213 25.8% 

San Francisco 

CA 741.0 -0.7% 698.6 2.9% $62,614 31.6% 

Area Total 4,598.4 5.6% 3,174.3 7.7% $53,974 25.9% 

California 36,154.1 14.1% 20,548.6 20.5% $36,936 15.8% 

United States 266,278.4 11.4 % 174,249.6 17.0 % $34,471 13.2 % 

Source: U.S. Department of Commerce 2007. 

Activity Levels 

Table 8-17 shows the recreation visits for San Francisco NWR. The Refuge had 1,505,410 visits in 2006. 

Non-consumptive recreation accounted for 1,497,911 visits, hunting 3,800 and fishing 3,700 visits. 

Residents accounted for 1,279,547 visits, or 85 percent of Refuge visits. 
Table 8-17. San Francisco NWR: 2006 Recreation Visits

Activity Residents Non-Residents Total 

Non-Consumptive:

Nature Trails 636,612 112,343 748,955 

Observation Platforms 0 0 0 

Birding 572,951 101,109 674,060 

Other Wildlife Observation 63,661 11,234 74,896 

Beach /Water Use 0 0 0 

Other Recreation 0 0 0 

Hunting:

Big Game 0 0 0 

Small Game 0 0 0 

Migratory Birds 2,660 1,140 3,800 

Fishing:

Freshwater 0 0 0 

Saltwater 3,663 37 3,700 

Total Visitation 1,279,547 225,864 1,505,410 

Regional Economic Analysis 

The economic area for the Refuge is comprised of the following California counties: Alameda, Santa 

Clara, San Mateo, and San Francisco. It is assumed that visitor expenditures occur primarily within this 

area. Visitor recreation expenditures for 2006 are shown in Table 8-18. Total expenditures were $16.0 

million with residents accounting for 9.7 million or 61 percent of total expenditures. Expenditures on nonconsumptive activities accounted for 98percent of all expenditures, followed by hunting and fishing at 2 

and less than 1 percent respectively. 

Table 8-19 summarizes the local economic effects associated with recreation visits. Final demand totaled 

$15.1 million with associated employment of 196 jobs, $8.3 million in employment income and $3.8 

million in total tax revenue.
Table 8-18. San Francisco NWR: Visitor Recreation Expenditures 

(2006 $,000) 

Activity Residents Non-Residents Total

Non-Consumptive:

Birding $4,281.5 $2,754.4 $7,035.9 

Other Non-Consumptive $5,233.0 $3,366.5 $8,599.4 

Total Non-Consumptive $9,514.5 $6,120.8 $15,635.3 

Hunting:

Big Game ― ― ―

Small Game ― ― ―

Migratory Birds $99.4 $147.7 $247.0 

Total Hunting $99.4 $147.7 $247.0 

Fishing:

Freshwater ― ― ―

Saltwater $123.9 $4.1 $128.0 

Total Fishing $123.9 $4.1 $128.0 

Total Expenditures $9,737.7 $6,272.7 $16,010.4 

Table 8-19. San Francisco NWR: Local Economic Effects Associated with Recreation Visits 

(2006 $,000) 

Residents Non-Residents Total 

Final Demand $15,083.4 $9,712.5 $24,795.9 

Jobs 123 73 196 

Job Income $5,071.3 $3,226.2 $8,297.5 

Total Tax Revenue $2,324.3 $1,505.4 $3,829.7 

Table 8-20 shows total economic effects (total recreation expenditures plus net economic value) 

compared with the refuge budget for 2006. For an individual, net economic value is that person's total 

willingness to pay for a particular recreation activity minus his or her actual expenditures for that activity. 

The figure for economic value is derived by multiplying net economic values for hunting, fishing, and 

non-consumptive recreation use (on a per-day basis) by estimated refuge visitor days for that activity. 

This figure is combined with the estimate of total expenditures and divided by the refuge budget for 2006. 

The $43.55 means that for every $1 of budget expenditures, $43.55 of total economic effects are 

associated with these budget expenditures. This ratio is provided only for the purpose of broadly 

comparing the magnitude of economic effects resulting from refuge visitation to budget expenditures and 

should not be interpreted as a benefit-cost ratio. 
Table 8-20. San Francisco NWR: Summary of Local Economic Effects of Recreation Visits 

(2006 $,000) 

FY 2006 

Budget Expenditures Economic Value

Total economic effects per 

$1 budget expenditure

San Francisco 

NWR

$763.0 $16,010.4 $17,221.7 $43.55 

Appendix C. Compatibility Determinations

Compatibility determinations are available for:

• Research and Monitoring

• Livestock Grazing

• Mosquito Management Plan

• Wildlife Observation and Photography 

• Environmental Education and Interpretation

• Waterfowl Hunting

• Recreational Boating

• Recreational Fishing

Compatibility Determination for Research and Monitoring

Don Edwards San Francisco Bay NWR

Use: Research and Monitoring

Refuge Name: Don Edwards San Francisco Bay National Wildlife Refuge, Alameda, Santa Clara 

and San Mateo Counties, California.

Establishing and Acquisition Authorities: 

86 Stat. 399, dated June 30, 1972

An Act Authorizing the Transfer of Certain Real Property for Wildlife, or other purposes (16 

U.S.C. 667b)

Endangered Species Act of 1973 (16 U.S.C. 1534) 

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

 

Refuge Purpose(s): 

“... for the preservation and enhancement of highly significant wildlife habitat ... for the protection 

of migratory waterfowl and other wildlife, including species known to be threatened with 

extinction, and to provide an opportunity for wildlife-oriented recreation and nature study ...” (86 

Stat. 399, dated June 30, 1972).

“... particular value in carrying out the national migratory bird management program” 16 U.S.C. 

667b (An Act Authorizing the Transfer of Certain Real Property for Wildlife, or other purposes).

“... to conserve (A) fish or wildlife which are listed as endangered species or threatened species.... 

or (B) plants ...” 16 U.S.C. 1534 (Endangered Species Act of 1973).

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

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

Service, in performing its activities and services. Such acceptance may be subject to the terms of 

any restrictive or affirmative covenant, or condition of servitude ...” 16 U.S.C. 742f (b)(1) (Fish and 

Wildlife Act of 1956).

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” (National Wildlife 

Refuge System Administration Act of 1966, as amended [16 U.S.C. 668dd-668ee]).

Description of Use: This compatibility determination is done as a review of the existing 

compatibility determination (1994) for research and monitoring, and in concert with the Don 

Edwards San Francisco Bay NWR Comprehensive Conservation Plan. This compatibility 

determination replaces the previous 1994 compatibility determination for research and monitoring.

Two provisions of the National Wildlife Refuge Improvement Act are to “maintain biological 

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integrity, diversity and environmental health” and to conduct “inventory and monitoring.” 

Research investigations are designed to address these provisions by answering specific 

management questions. These include, but are not limited to, evaluation of vegetation and wildlife 

response to habitat management techniques, wildlife and plant population monitoring, 

documentation of seasonal wildlife movements and habitat use, wildlife disease investigations, and 

development of invasive species management techniques. 

The Refuge receives numerous requests each year to conduct scientific research. The Refuge 

issues Special Use Permits (SUP) for approved research and monitoring projects. SUPs are only 

issued for monitoring and investigations, which contribute to the enhancement, protection, 

preservation, and management of native Refuge plant and wildlife populations and their habitats. 

Research applicants are required to submit a proposal that outlines: (1) objectives of the study; (2) 

justification for the study; (3) detailed methodology and schedule; (4) potential impacts on Refuge 

wildlife or habitat, including disturbance (short and long term), injury, or mortality (this includes a 

description of measures the researcher will take to reduce disturbance or impacts); (5) research 

personnel required; (6) costs to Refuge, if any; and (7) progress reports and end products (i.e., 

reports, thesis, dissertations, publications). Research proposals are reviewed by refuge staff, and if 

approved, a SUP is issued by the refuge manager to formally authorize any project.

Specific rules for research at the vernal pools that are located at the Warm Springs sub-unit of the 

Refuge are: 

• Research related to vernal pool vegetation/phylogeny and habitat characteristics 

• Basic research on vernal pool invertebrates and their habitat requirements

• Research on California tiger salamanders

• Research on the effects of grazing on vernal pool habitat and native vegetation

• Restoration science research

Examples of specific research and monitoring being conducted by non-Refuge staff as listed in the 

draft CCP include the following:

Salt Marsh Harvest Mouse

Research on the feasibility and ease of the restoration of high tide refugia for salt marsh harvest 

mice and clapper rails is happening on the Refuge around the levees of the newly tidal Pond A6. 

Aerial seeding and subsequent monitoring will begin in fall 2011.

Migratory Bird Surveys

As part of the South Bay Salt Pond Restoration Project, the Refuge is partnering with San Jose 

State University, SFBBO, and USGS to: 1) study waterbird response to trail use along new and 

existing trails in the South Bay; 2) determine the impacts of California gulls to nesting waterbirds 

including the snowy plover; 3) determine the carrying capacity of mudflats and ponds for foraging 

by shorebirds; and 4) determine the importance of islands for roosting waterbirds. Biofilm 

(microbes growing on the surface of the mudflats and potentially important for shorebird diet) is 

also being researched in South Bay mudflats in order to determine importance and distribution.

Other Research Projects

A number of other research projects occur on the Refuge in support of the SBSPRP or in support 

of other management goals. These projects include the following.

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• Radio telemetry of harbor seals (Phoca vitulina) and determination of selenium 

contamination in the fur of harbor seals (Moss Landing Marine Lab) 

• Distribution and abundance of western pond turtles (Clemmys marmorata) in the Moffett 

channel (NASA-Ames) 

• Assessing mercury levels and its impacts to wildlife in SBSPRP ponds (USGS, U.C. Davis, 

San Francisco Estuary Institute) 

• Sediment dynamics: accretion in natural and restored wetlands of south San Francisco Bay 

(University of San Francisco); interaction between bay and marsh waters (Stanford); 

analyzing and predicting sediment transport in newly restored ponds (Stanford); and 

sediment accretion and carbon sequestration (USGS)

In addition, a few projects happen on the highly saline ponds located on the Refuge due to the 

unique landscape they provide: a study of the haloviruses of the hypersaline waters in California 

(U. C. Santa Cruz) and high salinity methane sampling (NASA).

In evaluating research proposals submitted to the Refuge, priority would be given to research that 

contributes to the enhancement, protection, preservation and management of migratory birds, 

listed species, habitat and wildlife on the Refuge. Research proposals are reviewed by Refuge staff 

and conservation partners, as appropriate. If the proposal is approved, a Refuge SUP would be 

issued by the Refuge manager or biologist. 

Research proposals would be assessed based on criteria including, but not limited to:

• Research and monitoring that will contribute to specific Refuge management 

challenges, CCP goals, or purposes for which the Refuge was established will be 

encouraged;

• Research and monitoring must be designed to minimize disturbance to the wildlife and 

habitat on the Refuge as well as the surrounding human environment; 

• Research and monitoring that will not conflict with other ongoing research, monitoring, 

or management programs;

• Research that can be accomplished off-Refuge is less likely to be approved;

• Research which causes exceptional disturbance to wildlife or undue habitat degradation 

will not be granted; 

• If staffing or logistics make it impossible for the Refuge to monitor research activity in 

a sensitive areas, proposal will not be granted; and

• Research would not be allowed to be conducted open-ended, but will be reviewed 

annually.

Availability of Resources: Some staff time would be required to review research requests and 

manage research activities. However, refuge staff would not be expected to commit weekly staff 

time to managing this use. Oversight and review of proposals, study plans, and reports require an 

estimated $10,000 in staff time. There is currently sufficient Refuge staffing to meet this estimated 

cost. Approving proposals will be based upon available staff to monitor the research. If there are 

not sufficient staff resources to monitor a specific proposed research project, it will not be 

approved. Other than staff time, no special equipment, facilities, or improvements are necessary to 

support this proposed use. Some equipment (e.g. kayaks, paddles) is loaned out on a case-by-case 

basis in support of research projects.

 

C-3
Item One-time Cost On-going Cost

Review of Proposals/Issuance of 

SUPs

$0 $4,000.00

Monitoring of SUPs $0 $6,000.00

Total $0 $10,000.00

Anticipated Impacts: Conducting research activities at the Refuge can result in gaining 

information that benefits to management of habitat and wildlife populations. Monitoring of wildlife 

and habitat on the Refuge would provide feedback on the effectiveness of activities taking place

allowing adaption of, and improvement of management activities. Some level of disturbance is 

expected from this use because they could occur in sensitive areas and may involve collecting 

samples or handling wildlife. Researcher disturbance would include altering wildlife behavior, 

going off designated trails, collecting soil and plant samples. Most of these effects would be shortterm because only the minimum of samples required for identification and/or experimentation and 

statistical analysis would be permitted. Captured and marked wildlife would be released. 

Sensitive periods, such as nesting season, will be avoided when possible. Individual animals may be 

temporarily flushed from their habitat during such monitoring. In addition, native vegetation, rare 

plants and newly planted native seedlings may be trampled. Non-native plants may also be 

introduced through researchers’ clothing, footwear, and equipment.

Overall, proper review and approval of appropriate research proposals should result in limited 

disturbance to wildlife and habitat, while resulting in maximum benefit to refuge management and 

scientific data on the San Francisco Bay Area ecosystem. 

Public Review and Comment: 

Public review and comments were solicited in conjunction with distribution of the Draft CCP/EA 

for Don Edwards San Francisco Bay NWR, released in May 2012. No comments were made 

directly in regard to this compatibility determination.

Determination: 

_______ Use is Not Compatible

___X___ Use is Compatible with Stipulations

The following stipulations are required to ensure compatibility: Research and monitoring 

proposals would be assessed for approval based on criteria including, but not limited to:

• Research that will contribute to Refuge purposes and the National Wildlife Refuge 

System mission.

• Research will contribute to specific Refuge management challenges and/or CCP goals.

• Research must be designed to minimize disturbance to the wildlife and habitat on the 

Refuge as well as the surrounding human environment;

• Research that will not conflict with other ongoing research, monitoring, or management 

programs/operations; 

• Research that can be accomplished off-Refuge with less impact on wildlife is less likely 

to be approved;

• Research which causes exceptional disturbance to wildlife or undue habitat degradation 

will not be granted; 

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• If staffing or logistics make it impossible for the Refuge to monitor research activity in 

a sensitive areas, proposal will not be granted; and

• Research would not be allowed to be conducted open-ended and will be reviewed 

annually.

• All researchers will be required to engage in procedures that will limit transport of nonnative species onto the Refuge (e.g., cleaning shoes and clothing prior and after entry 

on Refuge lands, vehicle tire checks prior to entry onto Refuge lands). 

• Some research will be subject to a Section 7 and/or Section 10 consultation of the 

Endangered Species Act, as appropriate. 

• Stipulations that typically apply to Warm Springs researchers:

o Researchers are required to drive along the gravel roads or walk. No off-road 

motorized vehicle use is permitted within Warm Springs.

o Researchers are required to provide 48-hours’ notice to the Warm Springs 

manager before accessing Warm Springs.

o Upon entering gated areas, each gate must be immediately closed and locked 

o Extreme care will be taken to avoid or minimize stepping on vernal pool 

vegetation.

Justification: Research and monitoring are needed to understand both positive and negative 

impacts of management activities on the Refuge as well as improve the understanding of the San 

Francisco Bay Area ecosystem. Results of monitoring and research provide the information 

needed to adjust management activities to lessen their impact on Refuge resources and/or improve 

activities to better achieve management objectives. Though research and monitoring can have 

negative impacts on wildlife and habitat, following the listed stipulations will result in only 

minimally invasive work being approved on the Refuge. Often research can be accomplished at 

substantial cost savings to the Refuge. After assessing the potential impacts from the uses 

proposed for the Refuge, we have found that allowing these uses would not materially interfere 

with or detract from the purposes for which the Refuge was established or the mission of the 

National Wildlife Refuge System.

Mandatory Reevaluation Date (provide month and year):

_________ Mandatory 15-Year Reevaluation Date (for priority public uses)

____X____ Mandatory 10-Year Reevaluation Date (for all uses other than priority 

public uses)

NEPA Compliance for Refuge Use Decision (check one below):

Conducted with Comprehensive Conservation Plan

______Categorical Exclusion without Environmental Action Statement

______Categorical Exclusion and Environmental Action Statement

__X___Environmental Assessment and Finding of No Significant Impact

______Environmental Impact Statement and Record of Decision

C-5

Compatibility Determination for Livestock Grazing

Don Edwards San Francisco Bay NWR

Use: Livestock Grazing

Refuge Name: Don Edwards San Francisco Bay National Wildlife Refuge, Alameda, Santa Clara 

and San Mateo Counties, California.

Date Established: June 30, 1972

 

Establishing and Acquisition Authorities: 

86 Stat. 399, dated June 30, 1972

An Act Authorizing the Transfer of Certain Real Property for Wildlife, or other purposes (16 

U.S.C. 667b)

Endangered Species Act of 1973 (16 U.S.C. 1534) 

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

Refuge Purpose(s): 

“... for the preservation and enhancement of highly significant wildlife habitat ... for the protection 

of migratory waterfowl and other wildlife, including species known to be threatened with 

extinction, and to provide an opportunity for wildlife-oriented recreation and nature study ...” (86 

Stat. 399, dated June 30, 1972).

“... particular value in carrying out the national migratory bird management program” 16 U.S.C. 

667b (An Act Authorizing the Transfer of Certain Real Property for Wildlife, or other purposes).

“... to conserve (A) fish or wildlife which are listed as endangered species or threatened species.... 

or (B) plants ...” 16 U.S.C. 1534 (Endangered Species Act of 1973).

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

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

Service, in performing its activities and services. Such acceptance may be subject to the terms of 

any restrictive or affirmative covenant, or condition of servitude ...” 16 U.S.C. 742f (b)(1) (Fish and 

Wildlife Act of 1956).

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” (National Wildlife 

Refuge System Administration Act of 1966, as amended [16 U.S.C. 668dd-668ee]).

Description of Use: This compatibility determination is done as a review of the existing 

compatibility determination (2004) for grazing and in concert with the Don Edwards San Francisco 

Bay NWR Comprehensive Conservation Plan. This compatibility determination replaces the 

previous 2004 compatibility determination for grazing, described as follows.

C-7
Cattle grazing currently occurs at the Warm Springs Sub-Unit and has occurred there throughout 

much of the 20th century. However, upon acquisition of Warm Springs in 1992, the Refuge ceased 

all grazing practices in the absence of a formal management plan. Over the next ten years, nonnative annual grasses accumulated in vernal pools, significantly altering plant community dynamics 

and wildlife habitat. Observations by Refuge staff revealed an apparent decline in abundance of 

native vernal pool plants and wildlife after suspension of grazing. These negative trends were 

consistent with available information from other vernal pool ecosystems that have experienced a 

sudden cessation of grazing. After extensive literature review and consultation with rangeland and 

vernal pool experts, the Refuge began the process to re-introduce grazing to Warm Springs. 

In 2004, cattle grazing was reintroduced to the site and biological monitoring was expanded. The 

herd grew slowly each year as new pastures were added to the program, from 20 cows in 2004 to 

105 cows in 2010. Grazing occurs year-round at Warm Springs, in that cows will remain in at least 

three pastures throughout the year and will not be moved off-site. Currently, there is a large herd 

of spring-calving cows, a smaller herd of fall-calving cows, and one or more small groups of 

heifers/steers (young animals). Additional pastures on adjacent lands, formerly known as the 

Pacific Commons Preserve, became part of the Refuge in 2008. The entire area is now known as 

Warm Springs. The Refuge is expected to begin management of the former Pacific Commons 

Preserve lands in 2012. Cows will be kept in several small herds and will be rotated seasonally 

throughout ten different refuge pastures, totaling approximately 700 acres. Pastures are 

separated with barbed wire fencing and are between 20 and 100 acres in size, allowing for a more 

uniform distribution of grazing pressure throughout Warm Springs.

Since the original goals were established in 2004, the Refuge has acquired over 440 acres of 

restored vernal pool habitat (the former Pacific Commons Preserve). This acreage supports native 

vegetation but has higher cover of weeds than the original Warm Springs Unit. In addition, we 

have gained knowledge of the system through extensive monitoring of vegetation and sensitive 

species as well as the effects of grazing. Finally, we are more aware of the logistic limitations of 

monitoring. Consequently, the goals of the program have been revised to the following (as 

discussed in this CCP):

1) Over the next five years, reduce biomass of residual dry matter (RDM) to 1000-1200 

pounds/acre over each of the Warm Springs subunits in order to improve germination 

conditions for native plant species and enhance vernal pool hydrologic function.

2) Over the next ten years, increase cover of native upland plants and native vernal pool 

forbs on Warm Springs by 10%.

3) Over the next fifteen years, reduce the cover of invasive plants on Warm Springs 

(excluding non-native annual grasses) to less than 20%.

Cattle grazing is a refuge management economic activity. The grazing program at Warm Springs 

is conducted through a Cooperative Land Management Agreement with a local rancher. In 

exchange for grazing rights on the land, the cooperator currently provides, and will continue to 

provide, the Refuge with services-in-kind equivalent to 100% of the value of the grazing land. The 

value of an Animal Unit Month (AUM) was determined in conjunction with a University of 

California Extension Grazing Advisor based on comparable grazing fees in the local area. One 

Animal Unit equals the dry forage consumption of a 1000-pound animal, or one mature cow with or 

without calf, assumed to average 30 pounds per day. In-kind services typically include herbicide 

spraying, fence repair, and road repair. Grazing fees will be re-examined every five years with the 

C-8
renewal of the Cooperative Land Management Agreement.

Prior to the beginning of the grazing season (October 1st), the Warm Springs manager will meet

with the grazer to develop a grazing plan for the year. A general timeframe for grazing rotations 

will be determined, but the timing for moving cattle on and off the different Warm Springs 

pastures will not be tied to specific dates. Instead, there will be flexibility in the plan to allow for 

the variable response of vegetation to annual rainfall and temperature conditions and ensure that 

no pastures are over or undergrazed. Additionally, the stocking rate (the number of animals 

grazing a unit for a specific time) will continue to vary from year to year, depending on annual 

precipitation. Because the program was purposely begun with a small herd and a conservative 

stocking rate, it is only in the last year or two that the stocking rate has approached target levels. 

The grazer will have some flexibility in increasing or decreasing stocking rates by deciding how 

many cows to sell each year. During drought years, for example, more cows would be sold than 

during normal or above-average rainfall years. 

Target stocking rates were initially developed for each pasture based on using 75% of the 

estimated grazing carrying capacity of a favorable year (Natural Resources Conservation Service 

(NRCS) estimates using soil types). However, it was determined that actual forage production at 

Warm Springs is much higher than the NRCS estimates (WRA 2010). Actual forage production 

was calculated for each pasture using RDM measurements (residual dry matter samples - the 

amount of old plant material left on the ground at the beginning of a new growing season) and 

grazing data (estimated forage intake by cattle can be calculated using known stocking rates). The 

initial NRCS target stocking rates were resulting in RDM levels substantially above the RDM 

targets. Therefore, the proposed modified target stocking numbers will be equal to 100% of the 

estimated carrying capacity for a favorable year. The Refuge will continue to monitor RDM and 

refuge resources and make changes to target stocking rates as needed.

In order to closely monitor the grazing program and other Refuge management, extensive 

hydrological and biological monitoring will continue to occur annually on Warm Springs. Aquatic 

dip-net surveys are conducted in the winter to document habitat use by vernal pool fairy shrimp 

(Branchinecta lindahli), endangered vernal pool tadpole shrimp (Lepidurus packardi), and 

threatened California tiger salamanders (Ambystoma californiense). Pool inundation times and 

maximum depths are recorded. In the spring, vernal pool vegetation data are collected using aerial 

cover classes in large plots. In addition, a grazing exclosure experiment was established in 2002, 

prior to the initiation of grazing, and this survey provides the most valuable information on the 

effects of grazing on vernal pool vegetation. Refuge staff set up four paired plots within vernal 

pools in a grazed pasture. In each pair, one plot was randomly selected to be fenced to exclude 

cattle and one was left open. Plots are situated a few meters from each other within the same 

vernal pool and are monitored during peak bloom. Later in the spring vegetation data is collected 

from upland portions of the Refuge, and invasive species data is collected in the summer. 

Permanent photo points are set up in each pasture and are photographed twice a year, in 

March/April and October. Finally, the monitoring season ends with collection of RDM samples in 

late September or early October. 

Changes to the grazing program (compared to those described in the 2004 compatibility 

determination) will be minimal and consist of opening up one previously ungrazed pasture, 

adjusting the stocking rate to reflect actual forage production, and allowing cattle to graze yearround. The 2008 acquisition of the former Pacific Commons Preserve has expanded the grazed 

Refuge acreage from approximately 200 acres to approximately 700 acres, giving the Warm 

C-9
Springs manager and the cooperative grazer more flexibility in adjusting cattle rotations and 

stocking rates.

Availability of Resources: Funding and staffing exists to manage the grazing program. Since the 

grazing of livestock is conducted under a Cooperative Land Management Agreement, a rancher 

provides the livestock and maintains the infrastructure at no cost to the Refuge in exchange for the 

right to graze on Warm Springs. The cost to the Refuge for the grazing program is oversight and 

monitoring of the grazing to minimize any potential negative impacts and achieve the Refuge goals. 

All costs for monitoring and oversight of the grazing program, including salaries of Refuge staff, is 

funded through a permanent endowment that was established as part of a mitigation program. 

Funds are not taken out of the annual Refuge budget.

Item Annual Costs

Wildlife Refuge Specialist GS-0485-11 

(0.2 FTE)

$18,200.00

Botanist

GS-404-7/9 (0.3 FTE)

$19,350.00

Monitoring equipment/supplies/special 

projects

$500.00

TOTAL $37,550.00

Anticipated Impacts:

Grazing at Warm Springs has improved vernal pool habitat, contributing to a reduction in nonnative vegetation, particularly annual grasses, and an increase in native vegetation over ungrazed 

areas (WRA 2011, FWS 2010, pers. Comm., Ivette Loredo, Warm Springs Manager, 2011). In 

2011, the effects of the grazing program were comprehensively analyzed using years of collected 

biological monitoring data to determine if grazing was meeting/approaching the initial goals set out 

in the program (WRA 2011). These original goals were (USFWS 2004):

1) Over the next ten years, reduce biomass of RDM to 200-500 pounds per acre in vernal 

pools and 800-1000 pounds per acre in uplands. 

2) Increase vernal pool surface area, depth, and inundation time by 10-25% over the next 

ten years 

3) Increase the cover of native vernal pool and upland plants by 15%. 

4) Reduce the cover of invasive species to less than 10 % cover over the next ten years. 

5) Establish short grass prairie habitat throughout the upland areas of Warm Springs to 

provide habitat that supports more than 5 pairs of burrowing owls within ten years. 

Although it has only been six full years of monitoring since grazing has been reintroduced, the 

results of the grazing analysis support that grazing at Warm Springs has contributed to the 

achievement of the program’s ten-year goals (WRA 2011). Grazing has substantially reduced 

RDM, increased native species cover, and maintained Contra Costa goldfield (CCG) populations 

and low invasive species cover. Although the target 15% increase for CCG cover was not met, 

grazing did succeed in maintaining CCG cover, while in the ungrazed plots, its cover approached 

and often fell to zero. Invasive species cover has been maintained below the Goal 4 target of 10% 

through a combination of grazing and invasive plant control efforts. 

Grazing is expected to continue to result in beneficial effects to native vegetation. Primary benefits 

associated with the grazing program include a reduction in the accumulation of dead plant material.

C-10
This residual dry matter, or RDM, is measured annually at the end of the growing season to assist 

in monitoring the grazing program. High RDM values, which consist primarily of non-native 

annual grasses, have been associated with reduced native plant diversity in vernal pools (Barry 

1998). By preferentially consuming the taller, more palatable non-native grasses, cattle effectively 

increase light and nutrient availability for the native forbs during a key stage in their development. 

RDM measurements at Warm Springs have gone from approximately 5,000-6,000 pounds per acre 

in the absence of grazing to approximately 1,250-3,000 pounds per acre in 2009 and 2010 (the last 

two years of data). Although target RDM levels have not quite been reached, RDM is substantially 

lower in the grazed pastures and is approaching target levels. Further reductions in RDM levels 

are expected by adjusting stocking rate slightly higher, by approximately 5-8% (WRA 2011).

It is expected that the grazing program is improving habitat for the endangered vernal pool 

tadpole shrimp (VPTS) and the threatened California tiger salamander (CTS) by increasing 

maximum pool depths and inundation times. However, the effect of grazing on pool depths and 

inundation times is very difficult to measure due to the overwhelming influence of annual rainfall 

amounts and patterns on these variables. Accordingly, at Warm Springs, this annual climatic 

variation and the high variation among the pools themselves in size and depth made it impossible to 

determine whether grazing has had an effect on pond depth or duration (WRA 2011). Because of 

the inherent difficulty in measuring this effect, it has been eliminated as a measurable goal for the 

grazing program. However, the effect has been documented elsewhere and is expected to occur at 

Warm Springs. In a published study using a controlled large-scale experimental design, it was 

demonstrated that year round grazing in vernal pools increased pool inundation times and aquatic 

invertebrate diversity when compared to seasonal grazing or complete rest from grazing (Marty 

2005). Due to their high productivity, non-native annual grasses produce heightened levels of plant 

biomass along vernal pool edges as compared to native vernal pool species. As it accumulates, this 

organic matter decreases the net amount of water available for native species by increasing 

evapotranspiration rates, resulting in an overall reduction in pool inundation period (Bremer et al. 

2001, Frank 2003). By consuming the organic matter before it accumulates, cattle minimize these 

negative impacts of non-native annual grasses (Barry 1998, Robins and Vollmar 2001). At Warm 

Springs, pool inundation time has been the most reliable indicator of which pools will support 

VPTS and CTS because these species need a minimum amount of time (several weeks to several 

months) to complete their aquatic life stage. Marty (2005) hypothesizes that increased inundation 

time was the reason grazed pools had higher invertebrate diversity at her study site. 

The potential negative effects of grazing on VPTS and CTS are generally the result of over-grazing 

and include excessive trampling in vernal pools, increased nitrogen addition to pools, and the 

potential for cattle to cause pools to dry early by drinking from them. These effects have been 

hypothesized or observed in overgrazed study sites but most researchers and land managers 

currently agree that some level of grazing is important for maintaining ecosystem health within 

vernal pools (Robins and Vollmar 2001). Grazing generally is compatible with the continued use of 

rangelands by the CTS as long as best management practices are followed, intensive burrowing 

rodent control programs are not implemented in these areas, and grazing is not excessive (USFWS 

2009, Shaffer et al. 1993). At Warm Springs, the grazing program has been carefully managed to 

avoid over-grazing. The installation of 16 water troughs, placed in upland areas throughout Warm 

Springs, has been successful in preventing cattle from using pools as water sources (I. Loredo, 

pers. comm., 2011). Also, there is no evidence that grazing has negatively affected populations of 

VPTS or CTS at Warm Springs. In fact, since annual aquatic dip-net surveys began in 1999, the 

two best years for VPTS were in 2010 and 2011 and for CTS were in 2008 and 2010 (USFWS 2011, 

USFWS 2010), long after the initiation of grazing. 

C-11
Prior to the reintroduction of grazing, there was concern that grazing could negatively impact 

vernal pool vegetation, particularly the endangered CCG. However, cattle are known to selectively 

forage on grasses (Kie & Boroski 1996; Stoddart et al 1975) and help maintain a more open canopy 

(Weiss 1999) which benefits native vernal pool plants. Refuge staff have similarly observed that 

cows have shown a substantial preference for grazing on grasses and wild mustard over native 

vernal pool plants (I. Loredo, pers. comm., 2011). The experimental grazing exclosures within 

vernal pools have consistently shown that grazing reduces cover of non-native annual grasses and 

increases cover of native vernal pool forbs (see USFWS Annual Reports 2006-2011). Ungrazed

plots are dominated by non-native annual grasses, while grazed plots have, on average, 2.5 times 

higher cover of native vernal pool plants (WRA 2011). Vernal pool vegetation can vary 

dramatically both spatially (between pools within the same year) and temporarily (between years 

within the same pool). Therefore, the exclosure data is highly valuable because it allows managers 

to look at the same vernal pool during the same year, with and without grazing. Finally, in a largescale vernal pool grazing study, the continuously grazed pools had the highest relative cover of 

native species across all 3 years of the experiment, higher than both the ungrazed and seasonally 

grazed treatments (Marty 2005); similarly, Robins and Vollmar (2001), in a comprehensive review 

of grazing in vernal pool habitats, concluded that CCG populations thrived in regularly grazed or 

mowed sites and that ungrazed sites generally had smaller populations. As for upland plants, 

Refuge data show that grazed pasture have consistently higher cover of native plants than 

ungrazed pastures (WRA 2011). 

By reducing the thick layer of annual grass thatch, grazing may favor rodent species that require 

areas of open ground to forage and escape from predators (U.S. Geological Survey 2001). There 

also appears to be a strong association between grazed communities, burrowing rodents, and the 

presence of tiger salamanders (DiDonato 2006). Since grazing was reestablished in 2004, the 

abundance of ground squirrel burrows has notably increased (I. Loredo, pers. comm., 2011). 

Ground squirrel burrows are known habitat for CTS during the non-breeding season (Loredo et al. 

1996) and also provide habitat for the California burrowing owl. The presence of California ground 

squirrels may be the single most important determinant of whether burrowing owls use a given 

site (Barclay 2001). Although annual surveys for burrowing owls have not been regularly 

conducted at Warm Springs, burrowing owls have continuously been observed breeding at Warm 

Springs and annual monitoring of the adjacent Pacific Commons Area (prior to Refuge acquisition) 

demonstrated an expansion of the burrowing owl population (WRA 2007 and 2006). Indeed, 

properly managed livestock grazing has been shown to benefit burrowing owls (Kantrud and 

Kologiski 1982, MacCracken et al. 1985) and may favor other bird species as well, including 

ground-foraging birds such as killdeer and American Robin (Bock et al. 1993). 

Longer vernal pool inundation periods that result from grazing would also expand available habitat 

for shorebirds, wintering waterfowl, and neotropical migratory birds. Warm Springs supports 

breeding shorebirds and waterfowl, such as the American avocet, black necked stilt, killdeer, 

mallard, and Canada goose, that often begin nesting on vernal pool shorelines or islands while 

pools are still inundated (I. Loredo, pers. comm., 2011). 

Grazing can have both negative and positive effects on birds. In riparian areas and prairies, some 

species of nesting waterfowl and songbirds may be negatively impacted by grazing (Krueper 1993, 

Kirsch 1969). However, certain guilds of migratory shorebirds require short and/or sparse 

foraging habitat (Baker and Baker, 1973; Helmers, 1992). Colwell and Dodd (1995) found greater 

shorebird species diversity and abundance in grazed pastures in coastal California. Grazing at 

C-12
Warm Springs produces a mosaic of plant heights and therefore continues to provide available 

habitat for grass-nesting species (I. Loredo, pers. comm., 2011). Grazing improves plant species 

composition and structure so that short-term or species-specific impacts to wildlife and habitat are 

expected to be mitigated by long-term benefits to Refuge vegetation, native plants, and overall 

wildlife habitat quality. 

Potential impacts of grazing activities on the Refuge’s resources will be minimized because 

sufficient restrictions are and will be included in the Cooperative Land Management Agreement 

and as part of the annual grazing rotation plans.

Public Review and Comment: 

Public review and comments were solicited in conjunction with distribution of the Draft CCP/EA 

for Don Edwards San Francisco Bay NWR, released in May 2012. No comments were made 

directly in regard to this compatibility determination.

Determination: 

_______ Use is Not Compatible

___X___ Use is Compatible with Stipulations

The following stipulations are required to ensure compatibility: 

• Cattle will be the only livestock species permitted to graze at Warm Springs. Beef cattle 

will continue to be used over dairy cattle because their less social habits reduce the chance 

of excessive trampling in one area. 

• Cattle will only be permitted on Warm Springs when used to accomplish a specific, predefined habitat objective. 

• Water troughs will be available in each pasture in the upland habitat to ensure that cows do 

not use the vernal pools as a water source. 

• The livestock operator must have undisputed ownership of the livestock.

• A cooperative land management agreement will continue to be used to provide livestock for

the grazing program and management of infrastructure. The agreement will be 

administered to adjust grazing levels to match yearly conditions (mainly different levels of 

precipitation) to assure Refuge goals are achieved and no pastures are being overgrazed. 

• Monitoring of compliance, impacts, and condition trends will be executed by Refuge staff. 

Populations of threatened/endangered species as well as upland and vernal pool plant 

composition will be monitored to determine both positive and negative impacts from 

grazing. This will allow the Refuge to determine if habitat objectives are being met and 

detect the first sign of any negative effects of livestock on special status species and adapt 

grazing prescriptions accordingly. 

• Staff will make management changes as necessary to adapt to changing conditions and new 

C-13
information and can, at any time, direct the cooperative grazer to rotate cows out of 

pastures and/or reduce the total stocking rate. 

• Periodic review of the grazing program could result in additional measures to eliminate or 

reduce grazing impacts to refuge. 

Justification: The grazing program contributes to the enhancement, protection, conservation, and 

management of native Refuge wildlife populations and their habitats. When Warm Springs was 

acquired by the Refuge, the suspension of grazing at the site resulted in vernal pool habitat 

degradation. Similarly, in other study sites, exclusion of livestock from vernal pool habitat has 

been shown to result in increased cover of non-native annual grasses around pool margins and 

within pool bottoms, as well as reductions in the diversity and abundance of native species (Marty 

2005, Robins and Vollmar 2001, Lis and Eggeman 2000). After extensive research and planning, a 

supervised grazing program was established at Warm Springs in 2004. Grazing has had an overall 

beneficial impact to refuge resources including vernal pool vegetation. Grazing has decreased 

RDM, decreased cover of non-native annual grasses in vernal pools, increased cover of native 

vegetation, and improved habitat for aquatic species (WRA 2011, USFWS 2010). Grazing is closely 

monitored to minimize potential negative impacts on Refuge resources and to adapt to changing 

conditions. In our opinion, grazing will not conflict with the national policy to maintain the 

biological diversity, integrity, and environmental health of the Refuge (601 FW 3). It is determined 

that grazing within the Refuge, as described herein, will not materially interfere with or detract 

from the purposes for which the Refuge was established or the mission of the Refuge System. 

Mandatory Reevaluation Date (provide month and year):

_______ Mandatory 15-Year Reevaluation Date (for priority public uses)

___X___ Mandatory 10-Year Reevaluation Date (for all uses other than priority 

public uses)

NEPA Compliance for Refuge Use Decision (check one below):

Conducted with Comprehensive Conservation Plan

______Categorical Exclusion without Environmental Action Statement

______Categorical Exclusion and Environmental Action Statement

__X___Environmental Assessment and Finding of No Significant Impact

______Environmental Impact Statement and Record of Decision

References Cited:

Baker, M.C. and E.A.M. Baker. 1973. Niche relationships among six species of shorebirds on their 

wintering and breeding grounds. Ecological Monographs 43:193–212.

Barclay, J. 2001. Burrowing Owl Species Summary. Appendix IV In Final Burrowing Owl 

Mitigation and Management Plan for Colonel Allensworth State Historic Park. Unpubl. 

C-14
report, Albion Environmental, Inc., Santa Cruz, California.

Barry, S.J. 1998. Managing the Sacramento vernal pool landscape to sustain native flora. Pages 

236-240 in: C.W. Withum, E. Bauder, D. Belk., W. Ferren, and R. Ornduff (Editors). 

Ecology, Conservation, and Management of Vernal Pool Ecosystems – Proceedings from a 

1996 Conference. California Native Plant Society, Sacramento, CA.

Bock, C.E., V.A. Saab, T.D. Rich, and D.S. Dobkin. 1993. Effects of livestock grazing on 

neotropical migratory landbirds in western North America. In: D. M. Finch, and P. W. 

Stangel (Eds.). Status and management of neotropical migratory birds (pp. 296-309). 

United States Department of Agriculture, Forest Service, Rocky Mountain Forest and 

Range Experiment Station, General Technical Report RM-229. Fort Collins, Colorado.

Bremer, D. J., L.M. Auen, J. M. Ham, and C. E.Owensby. 2001. Evapotranspiration in prairie 

ecosystems: effects of grazing by cattle. Agronomy Journal 93:338–348.

Colwell, M.A. and S.L. Dodd. 1995. Waterbird communities and habitat relationships in coastal 

pastures of northern California. Conservation Biology 9:827–834.

DiDonato J. 2006. Endangered Amphibian Research within Grazed Grasslands. CAL-PAC 

Society for Range Management Symposium. 2 pages.

DiTomaso, J.M. 2000. Invasive weeds in rangelands: Species, impacts and management. Weed 

Sci. 48:255-265.

Frank, A.B. 2003. Evapotranspiration from northern semiarid grasslands. Agronomy Journal 

95:1504–1509.

Helmers, D.L. 1992. Shorebird Management Manual. Western Hemispheric Shorebird Reserve 

Network, Manomet, Massachusetts. 58 pp.

Kantrud, H.A. and R.L. Kologiski. 1982. Effects of soils and grazing on breeding birds of 

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Service, Wildlife Research Report 15. 33 pp.

Kie, J.G. and B.B. Boroski. 1996. Cattle distribution, habitats, and diets in the Sierra Nevada of 

California. J. Range Management 49:482.

Kirsch, L.M. 1969. Waterfowl production in relation to grazing. Journal of Wildlife Management 

33:821-828.

Knapp, A.K., J.M. Blair, J.M. Briggs, S.L. Collins, D.C. Hartnett, L.C. Johnson, and E.G. Towne. 

1999. The keystone role of bison in North American tallgrass prairie. BioScience 49:39-50.

Krueper, D.J. 1993. Effects of land use practices on western riparian ecosystems. Pages 321–330 

in: D.M. Finch and P.W. Stangel (Editors). Status and Management of Neotropical 

Migratory Birds. U.S. Forest Service, General Technical Report RM–229, Washington, D.C.

Lis, R. and E. Eggeman. 2000. Conservation and management of vernal pools through grazing 

C-15
and burning: Updating the vernal pool project. Outdoor California, 19-23.

Loredo, Ivette. 2011. Warm Springs Manager, personal communication.

Loredo, I., D. Van Buren, M. Morrison. 1996. Habitat use and migration behavior of the California 

tiger salamander. Journal of Herpetology, 30(2): 282-285. 

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nest sites in Conata Basin, South Dakota. Condor 87: 152-154.

Marty, J. 2005. Effects of cattle grazing on diversity in ephemeral wetlands. Conservation 

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Menke, J.W. 1992. Grazing and fire management for native perennial grass restoration in 

California grasslands. Fremontia 20(2):22-25.

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Vollmar editor. Wildlife and Rare Plant Ecology of Eastern Merced County’s Vernal Pool 

Grasslands. Report prepared by the California Department of Fish and Game as part of the 

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(Ambystoma californiense). Final report for the California Department of Fish and Game. 

36 pp. plus figures and tables.

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grazing on annual grasslands decreases yellow starthistle. California Agriculture 47:36-40. 

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Edwards San Francisco Bay NWR.

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National Wildlife Refuge.

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Compatibility Determination for Mosquito Management on Don Edwards San Francisco Bay 

National Wildlife Refuge

Use: Mosquito Management Plan

Refuge Name: Don Edwards San Francisco Bay National Wildlife Refuge, Alameda, San Mateo 

and Santa Clara Counties, California

Establishing and Acquisition Authorities: 

86 Stat. 399, dated June 30, 1972

An Act Authorizing the Transfer of Certain Real Property for Wildlife, or other purposes (16 

U.S.C. 667b)

Endangered Species Act of 1973 (16 U.S.C. 1534) 

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

Refuge Purpose(s):

“... for the preservation and enhancement of highly significant wildlife habitat ... for the protection 

of migratory waterfowl and other wildlife, including species known to be threatened with 

extinction, and to provide an opportunity for wildlife-oriented recreation and nature study ...” (86 

Stat. 399, dated June 30, 1972).

“... particular value in carrying out the national migratory bird management program” 16 U.S.C. 

667b (An Act Authorizing the Transfer of Certain Real Property for Wildlife, or other purposes).

“... to conserve (A) fish or wildlife which are listed as endangered species or threatened species.... 

or (B) plants ...” 16 U.S.C. 1534 (Endangered Species Act of 1973).

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

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

Service, in performing its activities and services. Such acceptance may be subject to the terms of 

any restrictive or affirmative covenant, or condition of servitude ...” 16 U.S.C. 742f (b)(1) (Fish and 

Wildlife Act of 1956).

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.” (National 

Wildlife Refuge System Administration Act of 1966, as amended [16 U.S.C. 668dd - 668ee.]

Description of Use(s): This compatibility determination is done as a review of the existing 

compatibility determination (1994) for mosquito management, and in concert with the Don 

Edwards San Francisco Bay NWR Comprehensive Conservation Plan and Mosquito Management 

Plan. This compatibility determination replaces the previous 1994 compatibility determination for 

mosquito management.

C-19
Mosquito management is an existing use conducted primarily to protect public health and safety. 

Since establishment of the Don Edwards National Wildlife Refuge (Refuge) in 1972, mosquito 

management on the Refuge has been conducted by local mosquito abatement districts 

(MADs/Districts), and monitored and regulated through annual U.S. Fish and Wildlife Service 

(Service) Pesticide Use Proposals. The Refuge lies within the jurisdiction of three MADs: Alameda 

County Mosquito Abatement District, San Mateo County Mosquito and Vector Control District, 

and Santa Clara County Vector Control District. Although the mosquito abatement districts do 

not have comparable funding, each district operates under similar policies and management 

directives set by their individual boards. The disparity in budgets leads to different approaches in 

mosquito management on the Refuge, particularly with reference to source reduction projects.

The proposed use is the implementation of a Mosquito Management Plan (Mosquito Plan) 

(USFWS 2012) that will be used as a guide for mosquito assessment and control activities on the 

Refuge. The Mosquito Plan contains a protocol for the surveillance of mosquito populations and 

describes the health threat criteria for determining when and how to allow the MADs to manage 

mosquito populations on the Refuge. The Mosquito Plan was developed in coordination with the 

Districts that will be responsible for conducting monitoring, surveillance, and treatment activities. 

In addition to the Mosquito Plan, the Districts will follow protocols identified in the Statement of 

Best Management Practices Proposed Monitoring Plan for Coastal Region Mosquito and Vector 

Control Districts (Appendix K2 of the Mosquito Plan).

Background and Rationale for the Use

Mosquito management activities are conducted throughout the San Francisco Bay region due to a 

large (>7 million) human population and a long history of mosquito-borne disease transmission to 

humans and wildlife. Mosquitoes are well known vectors of disease to both humans and wildlife, 

and in some cases these diseases can cause death. Ten California species of mosquito that are 

known vectors of arboviruses (arthropod-borne) were evaluated for West Nile Virus (WNV) 

transmission in 2002. In laboratory testing, all ten species were infected with WNV and were able 

to transmit the disease at some level (Goddard et al. 2002). Culex tarsalis is abundant in 

California and much of western North America, where the species is involved in the maintenance 

and amplification of western equine encephalomyelitis virus (WEEV) and Saint Louis encephalitis 

virus (SLEV) (Goddard et al. 2002). Of the ten mosquito species studied by Goddard et al. 2002, 

Culex tarsalis showed the greatest potential to amplify and maintain WNV in California. Mosquito 

species frequently found breeding on the Refuge include Aedes dorsalis (summer salt marsh 

mosquito), Aedes squamiger (winter salt marsh mosquito), Aedes washinoi (Washino’s mosquito), 

Culex erythrothorax (Tule mosquito), Culex tarsalis (encephalitis mosquito), and Culiseta 

inornata (winter mosquito). 

California reporting for WNV dates back to 2005. There has been 16 reported human case of WNV 

in Santa Clara County since 2005; four reported human cases for Alameda County since 2005; and 

one reported human case of WNV in San Mateo County since 2005 (http://www.westnile.ca.gov, 

accessed June 27, 2012). Table 1 summarizes information on WNV cases in the three counties 

where the Refuge is located.

C-20
Table 1. Cases of West Nile Virus by County, 2005-2011.

County Human cases Dead birds Mosquito 

samples

Sentinel 

chickens

Squirrels

Alameda

2011 - - - - 1

2010 1 1 - - -

2009 - 10 1 - -

2008 1 12 1 - 1

2007 - 19 1 - 1

2006 1 41 9 - 2

2005 1 48 8 - n/a

San Mateo

2011 - - - - -

2010 - - - - 6

2009 - 1 - - -

2008 - 2 - - -

2007 - 2 - - 1

2006 - 7 - - 2

2005 1 10 - - n/a

Santa Clara

2011 1 36 16 - 1

2010 - 32 10 - 6

2009 - 14 14 - 2

2008 1 13 1 - -

2007 4 83 10 - 6

2006 5 224 9 1 2

2005 5 144 3 - n/a

As of 2011, 326 bird species have been listed in the Center for Disease Control WNV avian 

mortality database (http://www.cdc.gov/ncidod/dvbid/westnile/birdspecies.htm, accessed May 2, 

2011). The list includes wildlife that inhabit tidal marsh such as waterfowl, grebes, heron, egrets, 

cormorants, songbirds (wrens, yellowthroats, song sparrows), and rails (California clapper rail 

(Rallus longirostris obsoletus), Virginia rail (Rallus limicola), common moorhen (Gallinula 

chloropus), American coot (Fulica americana). Other vertebrates known to be infected by WNV 

include horses, bats, chipmunks, skunks, rabbits, and squirrels. 

With the spread of WNV and the potential for spread of other mosquito-borne diseases across the 

country, pressure is increasing to manage mosquito populations that occur on lands of the National 

Wildlife Refuge System (NWRS), especially in urban areas such as the San Francisco Bay region. 

Managers of National Wildlife Refuge lands recognize that mosquitos are vectors of human and 

wildlife disease but also understand that mosquitoes are a natural component of wetlands, 

providing an important component of aquatic ecosystems. Because large populations of 

mosquitoes impose an elevated risk of disease for both humans and wildlife, monitoring and control 

of mosquito populations on the Refuge will be allowed. However, control will be limited to help 

ensure mosquito abatement activities are compatible with the establishing purposes of the Refuge.

Mosquito management on the Refuge will involve baseline actions of monitoring and surveillance of 

mosquito populations. A disease threat approach will inform management activities aimed at 

C-21
controlling mosquito populations. Activities will include those such as removal of artificial 

mosquito breeding habitat (such as tires, open containers, and other objects that pool water); tidal 

circulation enhancements and restoration; and chemical/biological applications based on a threat 

only when necessary (larvicide, pupacide, and adulticide) (see Table 2). Because mosquito 

population densities and disease incidence and prevalence will vary from year to year, mosquito 

management on the Refuge will not likely include all health threat levels in a given year. Access 

for mosquito population monitoring and control activities will be limited in sensitive species 

habitats and along tidal channels and sloughs. The improvement of hydrology within tidal marsh 

will be the primary and preferred mechanism for minimizing mosquito production. Actions will 

focus on improving habitat for native wildlife and plants as well as for decreasing mosquito 

breeding to below treatment threshold levels. While the Refuge’s Mosquito Management Plan 

(USFWS 2012) calls for follow similar control measures used over the past 10 years, there will be 

greater emphasis placed on communication/consultation between Refuge and vector control agency 

personnel and additional documentation needed for both strategic habitat conservation and 

adaptive management. Program managers of the MADs will coordinate with the Refuge manager 

prior to surveillance, monitoring, and control activities on the Refuge.

Table 2. Larval and Pupal Mosquito Thresholds for Alameda, Santa Clara, and San Mateo Mosquito and Vector 

Control Districts.

Species Common 

Name

Most Common Habitats Distance to 

Populated Area

Larval/Pupal 

Threshold

Notes

Aedes dorsalis Salt marsh 

mosquito

Salt marshes 0 meters - 5 miles ≥1 per 10 dips High pest 

significance

Aedes 

squamiger

Winter salt 

marsh 

mosquito

Salt marshes, reclaimed 

marshes

0 meters - 10 

miles

≥1 per 10 dips High pest 

significance

Aedes 

washinoi

Woodland pool 

mosquito

Temporary woodland pools 0 meters - 5 mile ≥1 per 10 dips High pest 

significance

Culex 

erythrothorax

Tule mosquito Lakes and ponds associated 

with tules

0 - 500 meters ≥1 per dip High pest 

significance, 

vector of 

encephalitis, 

WNV

Culex tarsalis Encephalitis 

mosquito

Creeks, marshes, temporary 

pools, 

roadside ditches, fresh water

0 meters - 5 miles ≥1 per 10 dips Moderate pest 

significance, 

vector of 

encephalitis, 

WNV

Culiseta 

inornata

Winter salt 

marsh 

mosquito

Marshes, temporary pools, 

roadside ditches

0 meters - 1 mile ≥1 per dip High pest 

significance

C-22
Description of the Mosquito Management Plan

Table 3, Health Threat Criteria for Mosquito Management on the Refuge shows the 5-tier health 

threat-response for mosquito management.

Table 3. Health Threat Criteria for Mosquito Management for the Refuge.

Threat 

Level

Condition Response

1 No documented existing health threat1.

Mosquito management issues have not been reported or 

identified by the appropriate public health authority4

or 

vector control district(s).

Monitoring and surveillance of areas surrounding the 

Refuge to inform management actions on the Refuge. 

Remove/manage artificial breeding sites such as tires, 

tanks, or similar debris/containers. Consult with MADs 

when planning wetland enhancement or restoration 

projects. 

2 Potential human or wildlife (incl. threatened and 

endangered species) health threat1(presence of vector 

spp., historical health threat, etc.), as documented by 

appropriate public health authority(ies) or vector control 

district(s).

Response as in threat level 1, plus: allow compatible 

monitoring and disease surveillance. Consider 

compatible non-pesticide management options to 

reduce the potential for above-normal mosquito 

production (e.g., restore/enhance tidal marsh hydrology).

3 Mosquito larvae threshold exceeded for human and/or 

wildlife health2on the Refuge as determined by 

standardized monitoring. Documented potential human 

or wildlife health threat (historic health threat, presence 

of vector species).

Response as in threat level 2, plus: allow compatible 

site-specific application of larvicide in areas with above 

average mosquito populations, as determined by 

monitoring. Conduct post larvicide monitoring to 

determine efficacy.

4 Mosquito larvae have begun to reach last instar stages 

or pupate reducing the efficacy of larvicides. Mosquito 

larval and pupal population thresholds2

exceeded on the 

Refuge. Mosquitoes produced by the Refuge pose a 

health threat1,4 as determined by the appropriate public 

health authority(s).

Response as in threat level 3, plus: if appropriate, 

increase the intensity and frequency of larvicides, allow 

compatible site-specific use of pupacides in areas with 

above average mosquito populations, determined 

through monitoring to be beyond control with larvicides. 

Increase monitoring and disease surveillance. Conduct 

post larvicide and pupacide monitoring to determine 

efficacy.

5 Mosquito-borne disease is documented on the Refuge 

or within flight range of vector mosquitoes on the 

Refuge. Risk Assessment rating is at least 2.63

. High 

risk for mosquito-borne disease (imminent risk of serious 

human disease or death, or an imminent risk of serious 

disease or death to populations of wildlife) within 

communities surrounding the Refuge has been 

documented by the appropriate public health authority4.

Response as in threat level 4, plus: Consider sitespecific adulticiding in areas with above average 

mosquito populations as determined by monitoring. 

Conduct post adulticide monitoring to determine 

efficacy.

1

An adverse impact to the health of human or wildlife populations from mosquito-borne disease identified and 

documented by Federal, State, and/or local public health authorities. Health threats are locally derived and are based 

on the presence of endemic or enzootic mosquito-borne diseases, including the historical incidence of disease, and the 

presence and abundance of vector mosquitoes. Health threat levels are based on current monitoring of vectors and 

mosquito-borne pathogens. 2

See Table 2. 

3

Risk Assessment is calculated by considering several factors as determined by California Mosquito-Borne Virus 

Surveillance and Response Plan (Appendix K8).

4

Appropriate public health authority(s) is a Federal, State, or local public health or wildlife management authority with 

jurisdiction inclusive of Refuge boundaries and/or neighboring public health authorities.

In Threat Level 1, an existing health threat has not been identified and mosquito management 

issues have not been reported or identified by the appropriate public health authority or MADs. 

To avoid possible increases in mosquito populations, the Refuge will eliminate artificial mosquito 

breeding habitat throughout the Refuge, such as tires, open containers, and other equipment or 

C-23
objects that pool water where mosquitoes may breed. Refuge staff will also consult with officials 

from the MADs whenever wetland enhancement or restoration projects (to increase tidal water 

exchange) are being planned on the Refuge. Consultation will allow the Refuge and the MADs to 

identify potential problems or opportunities related to mosquito production and management in the

future. These projects could involve mechanical changes to the topography within the marsh that 

allow for unrestricted tidal flow and exchange across the marsh. These improvements can include 

ditching (currently performed by some MADs), lowering of berms within the marsh, breaching of 

berms or levees within the marsh, or complete removal of berms, levees or any other structures 

that may inhibit water flows through the marsh. These activities may require additional NEPA 

analysis, federal and state permitting, as well as Endangered Species Act consultations.

In Threat Level 2, refuge management will focus on developing a proactive mosquito prevention 

and management program for mosquitoes is to determine mosquito species presence, locations, 

and abundance on refuge lands, and to identify potential or documented vectors of mosquito-borne 

diseases that represent a potential human health threat. Monitoring and surveillance activities on 

the Refuge will be well documented and annually submitted to Refuge staff by the MADs. To 

access traps and sampling stations MAD personnel will comply with best management practices 

enumerated in the Refuge’s Mosquito Management Plan. 

 

Refuge staff and visitors would be informed of an increased health threat associated with 

mosquito-borne disease activity. Personal protection measures such as wearing long sleeves, long 

pants, and mosquito repellant would be recommended to staff and visitors.

In order to avoid or minimize the use of pesticides, habitat management practices or wetland 

enhancement/restoration projects that improve wildlife habitat and reduce seasonal abundance of 

larval and adult mosquitoes should be implemented where possible. 

Mosquito population monitoring involves activities associated with collecting quantitative data to 

determine mosquito species composition and to estimate relative changes in mosquito population 

sizes over time.

 

The purpose of mosquito-borne disease surveillance involves activities associated with detecting 

pathogens causing mosquito-borne diseases, such as testing adult mosquitoes for pathogens or 

testing reservoir hosts for pathogens or antibodies. These activities assist in determining public 

health risks associated with mosquito-borne pathogens on or near the Refuge.

Monitoring of immature mosquitoes will be conducted by the MADs. The Mosquito Management 

Plan describes the methods the MADs will use for monitoring and surveillance. Monitoring and 

surveillance will be conducted primarily by foot. The use of motorized vehicles (ARGOs) is 

authorized, but will be limited to non-sensitive habitats, unless coordinated with Refuge staff. 

Field technicians within these agencies will maintain a list of known mosquito developmental sites 

on the Refuge and visit them during predominant periods of mosquito production. The timing and 

frequency of monitoring is based on a number of factors including history of mosquito production, 

tidal cycles, precipitation levels, and available resources. Mosquito populations are sampled using 

established protocols. Samples are examined in the field or laboratory by the MADs to determine 

the abundance, species, and life-stage of mosquitoes present. This information is compared to 

historical records and established thresholds and used to prescribe treatment to reduce risk of 

mosquito-borne disease outbreaks.

C-24
Although larval mosquito control is preferred, identifying all larval sources is not possible. 

Therefore, adult mosquito monitoring is also needed to pinpoint problem areas and locate 

previously unrecognized or new larval developmental sites. Adult mosquitoes are sampled using 

carbon dioxide traps on and off the Refuge. Mosquitoes collected using these methods are counted 

and identified to species. Information on adult mosquito abundance from traps is augmented by 

testing of dead birds and squirrels to detect WNV in the area. Sentinel chickens are also an 

indirect way of monitoring for the presence of virus in the mosquito population. Chickens are 

maintained in outdoor cages where they are exposed to host-seeking mosquitoes. If bitten by an 

infected mosquito, these birds will develop an immune response. Blood samples are taken from the 

chickens every bi-weekly to every two weeks to test for exposure to WNV, WEE, or SLE. No 

sentinel flocks are maintained on the Refuge; instead flocks are maintained in areas neighboring 

the Refuge.

If non-pesticide attempts to reduce mosquito populations are unsuccessful or are not feasible and 

mosquito larvae thresholds (See Table 2) have been exceeded (varies by district), application of 

larvicides would be considered. In Threat Level 3 locations of larvicide treatments would be based 

on standardized monitoring results (see Mosquito Plan). The preferred larvicide treatments are 

biorationals Bacillus thuringiensis israelensis (Bti) or Bacillus sphaericus (Bs), because of the 

bacterium’s limited non-target effects (Appendix K3 and K4 of the Mosquito Plan). Chemical 

larvicides treatments (methoprene) would be the second preferred method for larval control. Post 

larvicide monitoring would be conducted to determine efficacy.

Larvicides (Bti or Bs, and methoprene) are only effective on mosquitoes during early instar stages 

(up to the fourth) and do not control pupae. In Threat Level 4, if developing mosquitoes have 

reached the last instar stages or have pupated, then the application of site-specific pupacides in 

areas with above average mosquito populations would be considered. Because pupacides can 

negatively affect all invertebrates that require surface air (e.g., act as surfactants). For this 

reason, pupacides (Agnique) would only be used if large numbers of infected mosquitoes are 

considered an immediate threat to human health and thresholds developed by the appropriate 

public agency have been exceeded. Post larvicide and pupacide monitoring would be conducted to 

determine efficacy.

At the Threat Level 5, a risk of serious mosquito-borne human disease or death has been 

documented by the appropriate public health authority. Disease surveillance determines that 

there is a high risk for mosquito-borne disease within the vicinity of the Refuge. For example, 

pathogen presence in mosquito pool(s), wild birds, sentinel chicken flock(s), horses, or humans has 

been documented within the flight range of vector mosquito species present on the Refuge. These 

conditions in combination with adult mosquito populations above threshold levels on the Refuge 

would trigger consideration of a more aggressive treatment strategy, including the use of 

adulticides. 

Further, the use of adulticide would be considered in relation to the Mosquito-borne Virus Risk 

Assessment in the most current version of the California Mosquito-borne Virus Surveillance and 

Response Plan. The MADs would be required to include a risk assessment as part of their request 

to apply adulticides. The risk assessment evaluates a number of factors including environmental 

conditions, mosquito species presence, virus infection rate, sentinel chicken seroconversion, dead 

bird presence, and human cases to determine whether adulticide should be used or not.

C-25
In order to limit human contact with adulticides, visitors would not be allowed in those parts of the 

Refuge that are being treated with adulticides. Information about treatment scheduling, location, 

and pesticide would be posted on the Refuge website, at the Refuge Headquarters, and at the 

treatment location. Post adulticide monitoring would be conducted to determine efficacy.

In summary, application of adulticides on the Refuge would require the following steps:

• Prior approval from the National IPM Coordinator via Pesticide Use Proposal 

(PUPS)

• The MAD must present the Refuge manager with data supporting presence of a 

arboviral disease on the Refuge or within flight range of the vector mosquito 

species on the Refuge, including a Risk Assessment in the region

• The MAD must provide the Refuge manager with types/quantities of adulticides 

proposed and locations

• If beneficial, the MAD should conduct simultaneous application of larvicides with 

the adulticide application to prevent future adult outbreaks

Pesticide Approval Process

As a result of statute authority under the Migratory Bird Treaty Act, the Endangered Species Act 

and Service policy, the Service is required to consider whether use of specific pesticides would 

harm trust species (e.g., threatened and endangered species, migratory birds). The Service 

evaluates approval of specific pesticide use based on histories of adverse effects on non-target 

species and persistence in the environment. 

PUPs are prepared on an annual basis for Regional Office Integrated Pest Management 

Coordinator and National IPM Coordinator approval. The PUPs would include pesticides that 

MADs or other permitted groups propose for use as part of a mosquito management program on 

the Refuge. Pesticide Use Reports (PUR) are prepared by Refuge staff by the end of each 

calendar year following application of pesticides to control mosquitoes on the Refuge. To assist in 

tracking the use of pesticides in conjunction with mosquito management activities, the Refuge 

Manager will require MADs to prepare an annual quantitative summary of refuge mosquito 

monitoring and surveillance results, control activities on the Refuge (e.g., pesticides applied, 

amount of pesticides applied, locations of application, method of application), and regional disease 

surveillance. The report should be accompanied by maps showing specific areas where 

management activities occurred. Comparisons of mosquito management within and among years 

will be included to permit analysis of patterns that may indicate success of habitat management 

efforts or suggest the need for a new management approach. 

Methods used to reduce mosquito populations are primarily based on efficacy, cost, and minimal 

ecological disruption, including minimum effects on non-target organisms and natural systems of 

the Refuge. “Chemical pesticides should be used only where practical physical, cultural, and 

biological alternatives or combinations thereof, are impractical or incapable of providing adequate 

mosquito population control. Furthermore, chemical pesticides would be used primarily to 

supplement, rather than as a substitute for, practical control measures of other types. Whenever a 

chemical is needed, the most narrow ranging and specific pesticide available for the target 

organism in question should be chosen, unless consideration of persistence or other hazards would 

preclude that choice.” (7 RM 14.2). 

C-26
Special Use Permit Process

Long-standing NWRS policy addressing Administration of Specialized Uses (5 RM 17) guides 

issuance of special use permits (SUP) for economic uses, special events, access to closed areas, and 

other privileged uses. Conduct of mosquito management on a refuge by a MAD or other party is a 

specialized use and requires issuance of an SUP.

 

Each year, Refuge staff will work with the MADs to develop the SUP that will cover the 

surveillance, monitoring, and control activities allowed on the Refuge that year. An annual meeting 

between the Refuge and MAD managers will ensure that permits are current, communication is 

continuous, and concerns related to mosquito populations and other biological resources of the 

Refuge are addressed. In addition, prior to issuing the SUP, we will review the proposed yearly 

activities in relation to the Section 7 consultation, cultural resource compliance, and the 

Environmental Assessment to determine if any additional documentation will be necessary.

Mosquito Control Pesticides

Mosquito control pesticides can be categorized into 3 groups: larvicides, pupacides (surface 

films/surfactants), and adulticides. Compared with other forms of pest control, relatively few 

pesticides are available within each of these categories, and all differ with regard to efficacy and 

effects on non-target organisms. Additional information on pesticides presented here can be found 

in Appendices K3, K4, K5, K6, and K7 in the Refuge’s Mosquito Management Plan (USFWS 2012). 

The use of larvicides and pupacides will be routinely approved subject to review by the Regional 

Office Integrated Pest Management Coordinator acting under the authority of the National IPM 

Coordinator. Data from various sources (e.g., scientific literature) will be used to identify whether 

new preferred chemicals exist, as they become available. 

Before applying pesticides to Refuge lands in a non-emergency situation:

• Current monitoring data for larval, pupal, and adult mosquitoes which documents the need 

for mosquito management must be presented. 

• The most appropriate pesticide treatment options based on monitoring data for the 

relevant mosquito life stage must be determined. 

• Consideration must be made as to whether the pesticide will harm trust species and;

• The PUP must be approved. 

Pesticides currently allowed under this CD are described briefly in the following Tables 4, 5, and 6. 

More detailed information on these pesticides is presented in the Mosquito Management Plan 

(USFWS 2012).

C-27
Table 4. Pesticides Permitted for Use on the Refuge in 2012 by the Alameda Mosquito Abatement District.

Trade Name Type Rate & Unit Method Equipment Applications per 

year

VectoLex CG Larvicide, Bs 20 lbs/acre Hand Hand broadcast Not to exceed 10

VectoLex WDG Larvicide, Bs 1.50 lbs/acre Hand Hand broadcast Not to exceed 10

VectoLex WSP Larvicide, Bs 50 ITUs/mg Hand Hand broadcast Not to exceed 10

VectoBac 12AS Larvicide, Bti 16 oz/acre Backpack spray, low-volume 

spray, aerial

ATV, helicopter Not to exceed 20

VectoBac G Larvicide, Bti 10 lbs/acre Hand, herd seeder, aerial ATV, helicopter Not to exceed 20

Altosid Liquid 

Concentrate SR20

Larvicide, 

methoprene

1 oz/acre Backpack spray, boom 

spray, aerial

ATV, helicopter Not to exceed 10

Altosid Pellets 

WSP

Larvicide, 

methoprene

10 lbs/acre Hand ATV Not to exceed 10

Altosid XR 

Extended 

Residual Briquets

Larvicide, 

methoprene

35 lbs/acre Hand ATV Not to exceed 10

Altosid Briquets Larvicide, 

methoprene

4.90 lbs/acre Hand ATV Not to exceed 10

Altosid XR-G Larvicide, 

methoprene

20 lbs/acre Hand Hand-held Not to exceed 10

Mosquito 

Larvicide GB-1111 

(Clarke)

Larvicide, oil 640 oz/acre Backpack spray, boom spray ATV, truck Not to exceed 5

Agnique MMF Pupacide, 

monomolecular 

film

128 oz/acre Backpack spray, boom spray ATV, truck Not to exceed 2

Pyrenone 25-5 Adulticide, 

pyrethrin

0.87 oz/acre Backpack spray, boom spray ATV Not to exceed 5

Table 5. Pesticides Permitted for Use on the Refuge in 2012 by the San Mateo Mosquito and Vector Control 

District.

Trade Name Type Rate & Unit Method Equipment Applications per 

year

VectoBac 12AS Larvicide, Bti 32 oz/acre Backpack spray, boom 

spray, low-volume spray, 

aerial

ATV, helicopter Not to exceed 20

VectoBac G Larvicide, Bti 10 lbs/acre Hand, herd seeder truck Not to exceed 20

Teknar HP-D Larvicide, Bti 0.16 oz/acre Backpack spray, boom 

spray, low-volume spray

truck Not to exceed 20

VectoBac WDG Larvicide, Bti 0.44 lbs/acre Backpack spray, boom 

spray, low-volume spray

ATV Not to exceed 20

Altosid Liquid 

Concentrate SR20

Larvicide, 

methoprene

1 oz/acre Backpack spray, boom 

spray, low-volume spray, 

aerial

ATV, helicopter Not to exceed 20

Altosid Liquid 

Larvicide 

Mosquito Growth 

Larvicide, 

methoprene

4 oz/acre Backpack spray, boom 

spray, low-volume spray, 

aerial

ATV, helicopter Not to exceed 20

C-28
Regulator

Altosid Pellets 

WSP

Larvicide, 

methoprene

5 lbs/acre Hand ATV Not to exceed 20

Altosid XR-G Larvicide, 

methoprene

20 lbs/acre Hand Hand broadcast Not to exceed 20

Mosquito 

Larvicide GB-1111 

(Clarke)

Larvicide, oil 640 oz/acre Backpack spray, boom spray ATV, truck Not to exceed 5

Agnique MMF Pupacide, 

monomolecular 

film

128 oz/acre Backpack spray, boom spray ATV, truck Not to exceed 2

Pyrenone 25-5 Adulticide, 

pyrethrin

0.87 oz/acre Backpack spray, boom spray ATV Not to exceed 5

Table 6. Pesticides Permitted for Use on the Refuge in 2012 by the Santa Clara County Vector Control 

District.

Trade Name Type Rate & Unit Method Equipment Application per 

year

VectoLex CG Larvicide, Bs 20 lbs/acre Hand Hand broadcast Not to exceed 10

VectoLex WDG Larvicide, Bs 1.50 lbs/acre Hand Hand broadcast Not to exceed 10

VectoLex WSP Larvicide, Bs 50 ITUs/mg Hand Hand broadcast Not to exceed 10

VectoBac 12AS Larvicide, Bti 32 oz/acre Backpack spray, boom 

spray, low-volume spray, 

hand, aerial

Truck, Helicopter Not to exceed 10

VectoBac G Larvicide, Bti 10 lbs/acre Hand Truck Not to exceed 10

Teknar HP-D Larvicide, Bti 16 oz/acre Backpack spray, boom 

spray, low-volume spray, 

hand

Truck Not to exceed 10

Bactimos pellets Larvicide, Bti 8 lbs/acre Hand Truck Not to exceed 10

Summit B.t.i. 

Briquets

Larvicide, Bti 7000 

ITUs/mg

Hand Hand broadcast Not to exceed 10

Altosid Pellets 

WSP

Larvicide, 

methoprene

5 lbs/acre Hand Hand broadcast Not to exceed 10

Altosid XR-G Larvicide, 

methoprene

20 lbs/acre Hand Hand broadcast Not to exceed 10

Altosid Briquets Larvicide, 

methoprene

4.90 lbs/acre Hand ATV Not to exceed 10

Altosid XR 

Extended 

Residual Briquets

Larvicide, 

methoprene

35 lbs/acre Hand ATV Not to exceed 10

Altosid Liquid 

Larvicide 

Mosquito Growth 

Regulator

Larvicide, 

methoprene

4 oz/acre Aerial, backpack spray, low 

volume spray, boom spray, 

hand

Helicopter, Truck Not to exceed 10

Altosid Liquid 

Concentrate SR20

Larvicide, 

methoprene

1 oz/acre Aerial, backpack spray, Low 

volume spray, boom spray, 

hand

Helicopter, Truck Not to exceed 10

C-29
Availability of Resources:

Monitoring and control will be conducted by the MADs and coordinated through the Refuge 

Manager on an annual basis. Existing funds are available to support the Refuge Manager and 

other staff in coordinating this use. Refuge staff will take an active and, in most cases, a lead role 

in planning and implementing tidal circulation enhancement and wetland restoration projects 

aimed at improving wildlife habitat while reducing mosquito production. These restoration 

projects will be pursued as funding becomes available.

Anticipated Impacts:

Direct impacts of mosquito monitoring and control activities, by their very nature have no positive 

on target species. In addition to intentional adverse effects on mosquito populations, monitoring 

and control activities will result in temporary disturbance to possible deleterious effects to nontarget wildlife and habitat. Areas of vegetation may be crushed under foot or by use of ARGOs, 

with impacts ranging from temporary in nature to loss of habitat over time. Invasive weeds may be

introduced or spread by ARGOs and by foot. Indirect effects associated with mosquito control 

include reducing mosquito populations and other non-target species that serve as the base of food 

chains for wildlife species.

To avoid harm to wildlife or habitats, access to traps and sampling stations will comply with the 

Stipulations Necessary to Ensure Compatibility in a section near the end of this document. Prior 

to implementation of the Mosquito Management Plan, an Intra-Service Section 7 consultation with 

Ecological Services will be conducted to evaluate the biological impacts on listed species. The 

terms and conditions identified in the Section 7 consultation will be a requirement of the SUP.

Tidal Circulation Enhancement and Restoration Effects to Non-target Organisms

Effects of mechanical tidal circulation enhancements and restoration to non-target organisms could 

include at a minimum temporary disturbance or displacement from their habitat. In the event that 

ditching, berm or levee breaching, or removal actions are conducted, effects could include injury or 

death to some mammal and bird species. In order to avoid impacts to salt marsh harvest mouse 

and other mammal species and California clapper rail or other bird species, construction will be 

scheduled to avoid reproductive periods or extreme high tides. Other measures may include 

removal of vegetation within the construction area during low tide to significantly reduce the 

likelihood of mammal or bird presence. As site-specific projects are identified, potential effects to 

wildlife will be further analyzed. Best management practices or conservation measures to 

eliminate or minimize any negative effects will be identified in a restoration and enhancement 

project-specific environmental planning documents. 

 

Pesticide Toxicity and Other Effects to Non-target Organisms

Areas of the Refuge that require pesticide application for the purpose of mosquito management 

typically support lower quality habitat for native wildlife and plants typically due to poor tidal 

circulation. Therefore, potential indirect adverse impacts on the relative availability food resources 

as a result of pesticide application within these areas is likely to be limited. 

Birds

Impacts to birds may occur as a result of ground access via foot or mechanized vehicle (ARGO). 

Use of mechanized vehicles can trample vegetation where these species may occur. However, 

impacts are considered limited because areas that need mosquito management typically provide 

poor habitat quality to most birds and access to the sites will be limited to the non-breeding season. 

C-30
The use of pesticides for the purpose of mosquito management may directly or indirectly affect 

resident and migratory bird populations of the Refuge. Direct effects may occur from the direct 

contact of the pesticides on the birds. Indirect effects are related to the potential reduction in the 

invertebrate food supply. Bti has practically no acute or chronic toxicity to mammals, birds, fish, or

vascular plants (USEPA 1998) (Appendix K3 and K4 of the Mosquito Plan [USFWS 2012]). 

Potentially, Bti may kill midge larvae (family chironomidae). Chironomid (non-biting midge) 

larvae can be abundant in wetlands and form a significant portion of the food base for other 

wildlife, including birds (Batzer et al. 1993; Cooper and Anderson 1996; Cox et al. 1998). 

Methoprene showed no toxicity to slight toxicity to birds at high concentrations and repeated 

exposure (Appendix K3 and K6, USEPA 2001). As with Bti, concerns regarding potential negative 

impacts to chironomid larvae from methoprene exist. Some studies have suggested methoprene 

impacts other organisms that may form part of the food base for birds. McKenney and Celestial 

(1996) noted significant reductions in number of young produced in mysid shrimp at 2 ppb. Sublethal effects on the cladoceran, Daphnia magna, in the form of reduced fecundity, increased time 

to first brood, and reduced molt frequency have also been observed at concentrations 0.1 ppb 

(Olmstead and LeBlanc 2001). 

Monomolecular film is not known to cause direct chronic or acute avian toxicological effects to birds 

(Appendix K4). Monomolecular films are potentially lethal to any aquatic insect that lives on the 

water surface or requires periodic contact with the air-water interface to obtain oxygen, and 

therefore may result in a negative impact to the avian food base (e.g., Chironomid invertebrates) 

(see Appendix K3 and K4 in the Mosquito Plan [USFWS 2012]).

Pyrethrins are not considered toxic to birds (Milam et al. 2000, USEPA 2006) when applied at 

labeled rates. A terrestrial exposure model showed no acute or chronic risks to mammal or bird 

species (USEPA 2006). However, non-target effects to birds from pyrethrin application may occur 

as a result of reduced food base (e.g., Chironomid invertebrates) (see Appendix K4 and K7 in the 

Mosquito Plan [USWFWS 2012]). Pyrethrums (natural adulticides) are known to significantly 

reduce invertebrate populations, especially among Chironomids.

Impacts to birds as a result of physical access (trampling of vegetation, nests) and application of 

pesticides (food chain effects) as a result of mosquito management could occur, but is unlikely as 

these actions would not significantly affect bird populations of the Refuge given poor habitat 

conditions that exist in areas requiring mosquito management and limitations on access. The 

potential also exists for transmission of mosquito-borne disease that has been shown to cause 

mortality in birds (e.g., West Nile virus).

Mammals

Mosquito control has the potential to impact mammals in two ways – first, through physically 

accessing the site with mechanized vehicles, and second through the application of pesticides. The 

federally endangered salt marsh harvest mouse (SMHM) occurs throughout tidal marsh of the 

Refuge. In a report on SMHM of the Mare Island Naval Shipyard, Bias and Morrison (1993) 

reported direct and indirect adverse effects on SMHM habitats and populations caused by the use 

of mechanized vehicles in the tidal marsh. According to their personal observations, vehicle effects 

on habitat include compacted soil, destroyed vegetation, and documented the destruction of one 

salt marsh harvest mouse nest (Bias and Morrison 1993). In addition, repeated vehicle travel over 

the same areas creates paths through the pickleweed that increase access for predators. Lastly, 

they reported that vehicle travel can disrupt daily activity (e.g. movements) and has the potential 

C-31
to cause mortality of individual SMHM. Past and current aerial imagery from a variety of sources 

show visible paths where mechanized vehicles have traversed the marsh. 

The use of larvicides and pupacides for the purpose of mosquito management are not likely to 

directly affect native mammal populations of the Refuge. Adverse effects on mammals from Bti, 

methoprene, and Agnique (monomolecular film) are not expected (see Appendix K3 and K4 in the 

Mosquito Plan [USFWS 2012]) when applied according to the label instructions. Extensive acute 

toxicity studies indicated that Bti is virtually innocuous to mammals (Siegel and Shadduck 1992). 

These studies exposed a variety of mammalian species to Bti at moderate to high doses and no 

pathological symptoms, disease, or mortality were observed. Methoprene is not considered toxic to 

mammals (see Appendix K3 and K4 in the Mosquito Plan [USFWS 2012]). Impacts to the 

mammalian community as a result of reduced invertebrate populations are not expected because 

most mammal species that inhabit wetlands of the Refuge are herbivorous (invertebrates are not a 

primary component of their diet). Insectivorous species such as shrews (e.g., Sorex ornatus) do 

occur in wetlands of the Refuge and reduced arthropod populations may impact food availability 

for these species. 

The use of pyrethrin pesticides will also be permitted on the Refuge under conditions identified in 

Threat Level 5 of the Plan (Table 3). Oral exposure of pyrethrins could occur through consumption 

of plants or plant parts that have been sprayed (aerial application). A terrestrial exposure model 

showed no acute or chronic risks to mammal or bird species (USEPA 2006).

Reptiles and Amphibians

Mosquito monitoring and surveillance, mosquito control through application of pesticides, and tidal 

wetland restoration could disturb reptiles and amphibians. Reptiles are known to occur within 

both tidal and seasonal wetland areas of the Refuge. Pesticide effects on reptiles and amphibians 

may occur through reductions in insects that serve as a food source (Hoffman et. al. 2008), through 

direct individual effects from pesticide application or from trampling of individuals or habitat (e.g., 

access via ARGOs). These include the federally threatened California tiger salamander 

(Ambystoma californiense) found in the vernal pool habitats of the Refuge. Birds are often used 

as a surrogate for effects on reptiles and fish as a surrogate for amphibians (see effects in Birds 

section previously, Hoffman et al. 2008). Direct chronic effects have been found for the San 

Francisco garter snake from application of labeled rates of permethrin (synthetic pyrethroid, 

Hoffman et al. 2008). This species does not occur on the Refuge, however these finding suggest 

other reptiles may incur direct chronic effects. Limitations on vehicle access and during sensitive 

times of the year will help reduce impacts to reptiles and amphibians.

Fisheries

Mosquito monitoring and surveillance activities are not expected to adversely affect fish because 

these activities do not occur within open subtidal waters of the Refuge (e.g., sloughs, channels, 

open bay), and are not expected to adversely affect water quality (e.g., turbidity, dissolved oxygen). 

Negative effects on fish populations are not expected from proposed larvicides and pupacides (see 

Appendix K3 and K4 in the Mosquito Management Plan [USFWS 2012]). Bti is practically nontoxic to fish (Appendix K5 in the Mosquito Plan [USFWS 2012]). However, the application of 

adulticides has the potential to adversely affect fish populations. Pyrethrins are considered highly 

toxic to fish and invertebrates (see Appendix K4 and K7 in the Mosquito Plan [USFWS 2012], 

USEPA 2006). Central California coast steelhead (Oncorhynchus mykiss) and North American 

green sturgeon (Acipenser medirostris) are special status fish that have the potential to occur on 

the Refuge.

C-32
The frequency of conditions that would require use of adulticides on the Refuge has been rare over 

the past few decades. No requests for adulticide use have been made over the past several years. 

This pattern suggests that future use of adulticides on the Refuge would be rare. Application would 

only occur in swales and would not be applied to channels, sloughs, or other open water areas. If 

application of adulticide were to occur, the low frequency and relatively limited extent of 

application is not likely to cause significant adverse effects to fish and invertebrate populations. 

Invertebrates

Monitoring and surveillance activities are not expected to adversely affect invertebrate 

populations. Chemical treatment of mosquito populations on the Refuge has the potential to 

adversely affect invertebrates. The effect on local populations of invertebrate species over time 

with periodic and continued use of Bti is unknown but potential for negative effects is a possibility 

(see Appendix K3 and K4 in the Mosquito Management Plan [USFWS 2012]). Host range and 

effect on non-target organisms indicates that Bti is relatively specific to the Nematocera suborder 

of Diptera, in particular filter-feed mosquitoes (Culicidae) and blackflies (Simuliidae) (Glare and 

O’Callaghan 1998). Bti is pathogenic to some species of midges (Chironomidae) and Tipulidae, 

although to a lesser extent than mosquitoes and biting flies and is not reported to affect a large 

number of other invertebrate species (Glare and O’Callaghan 1998). Bti concentration may be 

important with regard to effects on nontarget organisms. Of particular concern is the potential for 

Bti to kill midge larvae (family Chironomidae). Chironomid (non-biting midge) larvae are often the 

most abundant aquatic insect in wetland environments and form a significant portion of the food 

base for other wildlife (Batzer et al. 1993; Cooper and Anderson 1996; Cox et al. 1998). Reduced 

invertebrate populations as a result of food web effects (e.g., reduction of nematoceran Diptera) 

have been shown in studies of Bti (Hershey et al. 1998).

Because methoprene is a juvenile hormone (JH) mimic and all insects produce JH, concerns about 

potential adverse effects on non-target aquatic insects when this pesticide is used for mosquito 

control (see Appendix K3 and K4 in the Mosquito Plan [USFWS 2012]). As with Bti, concerns 

include potential negative impacts on chironomid larvae due to their importance in food webs. As 

with any pesticide, toxicity is a factor of dose plus exposure. At mosquito control application rates, 

methoprene is present in the water at very small concentrations (4-10 ppb, initially). With regard 

to exposure, chironomid larvae occur primarily in the benthos, either within the sediments and/or 

within cases constructed of silk and detritus. Thus, differences may exist with regard to exposure 

to methoprene between chironomid and mosquito larvae, the latter occurring primarily in the 

water column. The published literature on the effects of methoprene to chironomids is not as 

extensive as that for Bti. However, evidence is found for potential toxicity to chironomid and other 

aquatic invertebrates from methoprene treatments. In summary, evidence exists for significant 

adverse non-target effects from methoprene even when applied at mosquito control rates. 

Monomolecular films are potentially lethal to any aquatic insect that lives on the water surface and 

requires periodic contact with the air-water interface to obtain oxygen (USFWS 2005). The film 

interferes with larval orientation at the air-water interface and/or increases wetting tracheal 

structures, thus suffocating the organism. As the film spreads over the water surface, larvae tend 

to concentrate, which may increase mortality from crowding stress (Dale and Hulsman 1990).

Pyrethrins are known to cause acute toxicological effects to benthic invertebrates at rates used for 

mosquito abatement (USEPA 2006). Because pyrethrins are broad-spectrum insecticides, they are 

potentially lethal to most insects. All adulticides are very highly toxic to aquatic invertebrates in 

C-33
concentrations as low as one part per billion (Milam et al. 2000). Because most adulticides can be 

applied over or near water when used for mosquito control, risks to aquatic invertebrates from 

direct deposition and runoff of the pesticides exist.

Public Review and Comment:

Public review and comments were solicited in conjunction with distribution of the Draft CCP/EA 

for Don Edwards San Francisco Bay NWR, released in May 2012. Many comments were made 

directly in regard to the Mosquito Management Plan and relevant to this CD. Comments relevant 

to this CD included the assertion that mosquito management is a refuge management activity that 

is conducted by a Service-authorized agent to fulfill one or more purposes of a refuge, and 

therefore should not be considered a use. The term “use” refers to any activity on a National 

Wildlife Refuge that is not a management activity conducted by refuge personnel for the purpose

of conservation of fish and wildlife resources. It does not imply an extractive activity. Because we 

do not conduct mosquito management operations ourselves, but allow it when necessary through 

agreements with mosquito control agencies, we believe mosquito management must be considered 

a use. The remaining comments and response regarding mosquito management are contained in 

Appendix O of the CCP.

Determination (Check One Below):

_______ Use is Not Compatible

___X___ Use is Compatible with the Following Stipulations

Stipulations Necessary to Ensure Compatibility:

General Stipulations

• The MADs will be required to minimize the use of pesticides (e.g., choosing less toxic 

materials, using smaller quantities of more toxic chemicals, conducting fewer applications) 

and continually investigate formulations and compounds that are least damaging to fish and 

wildlife (including invertebrate) populations. 

• Each MAD will be required to review the past year’s Pesticide Use Proposals and submit 

any changes in the pesticides or formulations of pesticides that they expect to use in the 

upcoming year. This information will be made available at or before the time of the annual 

meeting.

• New products will not be applied without prior Refuge approval. 

• Mosquito control will be authorized on a biennial basis by a SUP. The SUP conditions will 

stipulate that all mosquito control work will be carried out under the guidance of preapproved PUPs.

• Pesticides will be applied according to pesticide label instructions and per habitat type.

• Aerial mosquito control application is encouraged over ground-based application methods.

• Aerial mosquito control applications will avoid low level flight over water to access or exit 

the Refuge as possible, thus minimizing bird disturbance. 

• Application of larvicides and pupacides will be discouraged during high tide events in order 

to avoid impacts to tidal marsh species.

• Unless permitted by the Refuge Manager, pesticide application should not occur within 100 

feet of major natural sloughs and channels that can disperse into navigable waterways and 

open water.

C-34
• Application of pesticides will be informed by monitoring of mosquito vector populations and 

surveillance indicating location of disease prevalence.

• MADs will adapt methods to reduce ecological risk to the environment (e.g., boom height, 

droplet size, application rate) as new information on ecological risk and avoidance measures 

are identified by appropriate regulatory agencies.

• To reduce the spread of non-native invasive plants all construction equipment, vehicles and 

personnel gear will be cleaned of seeds, soil or plant material before arriving on site.

• Oil and other hazardous material spill contingency plans must be implemented.

• Marsh vegetation is to be hand mowed and removed down to the bare ground before 

dredging occurs to prevent harm to the salt marsh harvest mouse.

• Areas of marsh vegetation that are submerged in water do not need to be mowed before 

dredging occurs. 

• Before excavation occurs, crews must walk ahead of the equipment and haze mice out of 

vegetation.

• When clearing vegetation from an area, begin mowing from the center of the area to be 

cleared and work toward the edges to avoid trapping mice in remaining patches of 

vegetation.

• Mowed vegetation should be cleared from the area and stockpiled for later re-use if 

possible.

• A final report on activities will be provided by MADs by the end of the treatment year. 

MADs will provide dates of mosquito sampling and treatment, mapped locations and 

methods of sampling/treatment sites, species of mosquito and their population 

indices/frequencies.

Motor Vehicle Operation:

• Mechanized vehicles will only be allowed on levees and existing roads unless approved by 

the Refuge Manager.

• Techniques for approved ARGO operations are such that limit impact, including: slow 

speeds; slow, several point turns; and using existing levees or upland to travel through sites 

when possible.

• Access along tidal channels and sloughs is restricted in order to reduce impacts to 

vegetation used as habitat by wildlife (e.g., nesting and escape habitat).

• MADs are required to attend Refuge-approved training on measures to avoid impacts to 

wetland wildlife and in identification of sensitive species.

• Aerial pesticide (larvicide or pupacide) application is encouraged over ground-based 

application methods in areas with endangered species.

• Boat access to Corkscrew Slough, Calaveras Point and Mowry Slough will be limited to the 

center channel during the harbor seal pupping season, March 15-June 15 to prevent 

flushing of pups from their mothers.

Endangered Species Habitat:

• Inspections and treatments will be primarily performed on foot, when possible.

• Aerial pesticide (larvicide or pupacide) application is encouraged over ground-based 

application methods in areas with endangered species.

• Access (via foot or mechanized vehicle) to tidal marsh and muted tidal marsh for the 

purpose of mosquito management would not be allowed access from February 1 to July 15 

in areas that are inhabited by California clapper rails without authorization of the Refuge 

Manager. 

C-35
• Access (via foot or mechanized vehicle) to seasonal pond habitats for the purpose of 

mosquito management would not be allowed access from March 1 to September 15 in areas 

used by nesting snowy plovers without authorization of the Refuge Manager. 

• Trucks and ARGOs would be restricted to established roads and berms in vernal pools 

areas. Only small, all-terrain vehicles will be permitted near vernal pools. Refuge staff will 

advise MAD staff on areas appropriate for motor vehicles. Only trained staff will be 

allowed to access vernal pools on foot in order to limit impacts to dispersing California tiger 

salamanders. 

• MAD staff will avoid driving and stepping on Contra Costa goldfields. Refuge staff will 

provide a map of known Contra Costa goldfield sites and MAD staff will avoid driving in 

these areas during Contra Costa goldfield germination (coincides with vernal pool draw 

down) and blooming period.

Use of Pyrethrins: 

• Use of adulticides must meet the following criteria: (1) when mosquito-borne disease 

incidence has been documented on the Refuge or within flight range of vector mosquito 

species present on the Refuge; (2) when any adult vector mosquito thresholds (varies by 

district) are exceeded on the Refuge; and (3) when there are no practical and effective 

alternatives to reduce a mosquito-borne, disease-based health threat.

• Adulticides must be approved for use by the Service’s National IPM Coordinator.

• The application of pyrethrums must be limited to reduce impacts to habitat and wildlife 

(i.e., during the time period when there is a mosquito-borne virus detected on or in 

mosquito flight range of the Refuge, or high risk to public health was documented), but 

sufficient to ensure effective mosquito control.

• The application of pyrethrums should occur at an ultra-low volume (according to pesticide 

label instructions and per habitat type).

• If beneficial, the MAD should conduct simultaneous application of larvicides with the 

adulticide application to prevent future adult outbreaks. 

• Application would only occur during low tides to avoid impacts to fish that may move into 

the tidal marsh plain during high tides.

• The application of pyrethrums should occur only where monitoring and surveillance data 

justify its use (e.g., incidence of mosquito-borne disease, exceedance of tolerance limits for 

adult mosquitoes).

• Refuge staff and visitors must be notified prior to adulticide treatments. Information about 

treatment scheduling, location, and type of pesticide must be posted by the MADs in areas 

where treatments would occur when those areas could be accessible to Refuge staff or the 

public.

• The application of pyrethrins should occur only in specific, discrete areas where monitoring 

data justify its use.

Justification:

Mosquitoes are a natural component of tidal wetlands but pose a significant potential threat to 

human and/or wildlife health. This potential threat is especially significant where Refuge wetlands 

are within the known mosquito flight ranges of urbanized areas. The arbovirus labeled WNV has 

been of particular concern across the United States and in the San Francisco Bay region and 

mosquito species known to occur on the Refuge have been shown to transmit WNV and other 

diseases that affect humans and/or wildlife. 

C-36
Measures to control mosquitoes in wetlands of the Bay Area have a long history that dates back to 

the early 1900s when the first mosquito district was formed in Marin County, California. The 

association between mosquitoes and certain vector-borne diseases is also well known (e.g., WNV). 

Historic measures for reducing mosquitoes includes draining or filling wetlands, but today a suite 

of other measures are now in place and include the placement and maintenance of mosquito 

ditches, tidal circulation enhancement and wetland restoration and application of biological and 

chemical controls. Today, the staff of both the Refuge and the MADs that operate in San 

Francisco Bay advocate for an integrated approach to mosquito management that includes a range 

of tools to improve habitat conditions for estuarine wildlife while reducing threats to public health 

from mosquito species capable of transmitting disease to humans. 

With the continued existence of WNV and the potential for spread of other mosquito-borne disease,

pressure is increasing to manage mosquito populations that occur on lands of the NWRS, 

especially in urban areas such as the San Francisco Bay region. There was one reported human 

case of WNV in Santa Clara County in 2011. The last reported human case of WNV in Alameda 

County was 2010. There were no humans cases of WNV reported in San Mateo County from 

available state reports (2007 to present). (http://www.westnile.ca.gov, accessed September 26, 

2011)

A “Draft Mosquito and Mosquito-Borne Disease Management Policy” was published by the 

Service in October 2007, but has not yet been finalized. The Service’s “Interim Guidance for 

Mosquito Management on National Wildlife Refuges” finalized in April 2005, provides guidance for 

mosquito management that is currently conducted on national wildlife refuges. The interim 

guidance provides a standard process for refuges to follow and criteria to consider when making 

decisions regarding management of mosquitoes and mosquito-borne disease. Mosquito control 

management plans and documentation of management actions on refuges are necessary to protect 

both threatened and endangered plants, fish, and wildlife and to ensure the health and welfare of 

surrounding human populations. This use is in compliance with the Interim Guidance. The 

stipulations ensure that the proposed use is compatible and would not materially interfere with or 

detract from fulfilling the refuge purposes and the Refuge System mission.

Mandatory Re-evaluation Dates (Provide Month and Year)

_______ Mandatory 15-year Reevaluation Date (for priority public uses)

___X___ Mandatory 10-year Reevaluation Date (for all uses other than priority public uses)

NEPA Compliance for Refuge Use Decision (Check One Below)

_______ Categorical Exclusion 

___X___ Environmental Assessment and Finding of No Significant Impact

_______ Environmental Impact Statement and Record of Decision

C-37
References Cited:

Batzer, D.P., M. McGee, V.H. Resh, and R.R. Smith. 1993. Characteristics of invertebrates 

consumed by mallards and prey response to wetland flooding schedules. Wetlands 13: 41-

49.

Bias, M.A. and M.L. Morrison. 1993. Final Report: Salt Marsh Harvest Mouse on Mare Island 

Naval Shipyard, 1989-1992. Unpubl. Rpt. Natural Resources Management Branch, 

Western Division, Naval Facilities Engineering Command, San Bruno, Calif. 223pp.

Cooper, C.B. and S.H. Anderson. 1996. Significance of invertebrate abundance to dabbling duck 

brood use of created wetlands. Wetlands 16: 557-563.

Cox, R.J., M.A. Hanson, C.C. Roy, N.J. Euliss, D.H. Johnson, and M.G. Butler. 1998. Mallard 

duckling growth and survival in relation to aquatic invertebrates. Journal of Wildlife 

Management 62: 124-133.

Dale, P.E.R. and K. Hulsman. 1990. A critical review of salt marsh management methods for 

mosquito control. Review in Aquatic Sciences 3:281-311.

Glare, T.R. and M. O’Callaghan. 1998. Environmental and health impacts of Bacillus thuringiensis 

israelensis. Report for New Zealand Ministry of Health. 58 p.

Goddard, L.B., A.E. Roth, W.K. Reisen, and T.W. Scott. 2002. Vector competence of California 

mosquitoes for West Nile Virus. Emerg. Infect. Dis.: 8. 

http://www.cdc.gov/ncidod/EID/vol8no12/02-0536.htm. 

Hershey, A.E., A.R. Lima, G.J. Niemi, and R.R. Regal. 1998. Effects of Bacillus thuringiensis 

israelensis (BTI) and methoprene on nontarget invertebrates in Minnesota wetlands. Ecol. 

Appl. 8:41-60.

Hoffmann, M., J.L. Melendez, M.A. Mohammed. 2008. Risk of permethrin use to the federally 

threatened California red-legged frog and bay checkerspot butterfly, and the federally 

endangered California clapper rail, salt marsh harvest mouse, and San Francisco garter 

snake. Pesticide Effects Determination. Environmental Fate and Effects Division, Office 

of Pesticide Programs, Washington, DC. 

McKenney, C.L. and D.M. Celestial. 1996. Modified survival, growth and reproduction in an 

estuarine mysid (Mysidopsis bahia) exposed to a juvenile hormone analogue through a 

complete life cycle. Aquatic Toxicology 35: 11-20.

Milam, C.D., J.L. Farris, and J.D. Wilhide. 2000. Evaluating Mosquito Control Pesticides for 

Effect on Target and nontarget Organisms. Archives of Environmental Contamination and

Toxicology 39: 324-328.

Olmstead, A.W. and G.L. LeBlanc. 2001. Low exposure concentration effects of methoprene on 

endocrine-regulated processes in the crustacean Daphnia magna. Toxicological Sciences 

62: 268-273.

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Siegel, J.P. and J.A. Shadduck. 1992. Mammalian safety of Bacillus thuringiensis israelensis and 

Bacillus sphaericus. Pp. 202-217 in de Barjac, Huguette and Donald J. Sutherland, eds. 

Bacterial control of mosquitos and blackflies: biochemistry, genetics, and applications of 

Bacillus thuringiensis israelensis and Bacillus sphaericus. Kluwer Academic.

USEPA. 2006. Reregistration eligibility decision for pyrethrins. 108pp. Available at: 

http://www.epa.gov/oppsrrd1/REDs/pyrethrins_red.pdf

USEPA. 2001. Pesticide Fact Sheet: Methoprene. 9pp. Available at: 

http://www.epa.gov/oppbppd1/biopesticides/ingredients/factsheets/factsheet_105401.pdf

U.S. Fish and Wildlife Service (USFWS). 2005. Interim Guidance for Mosquito Management on 

National Wildlife Refuges. 20pp. 

USFWS. 2012. Don Edwards San Francisco Bay National Wildlife Refuge Mosquito Management 

Plan. Appendix M of the Don Edwards San Francisco Bay National Wildlife Refuge Final 

Comprehensive Conservation Plan. Don Edwards San Francisco Bay National Wildlife 

Refuge, Fremont, CA.

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Compatibility Determination for Wildlife Observation & Photography

Don Edwards San Francisco Bay NWR

Use: Wildlife Observation and Photography

Refuge Name: Don Edwards San Francisco Bay National Wildlife Refuge, Alameda, 

Santa Clara and San Mateo Counties, California. 

Establishing and Acquisition Authorities: 

86 Stat. 399, dated June 30, 1972

An Act Authorizing the Transfer of Certain Real Property for Wildlife, or other purposes (16 

U.S.C. 667b)

Endangered Species Act of 1973 (16 U.S.C. 1534) 

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

 

Refuge Purpose(s): 

“... for the preservation and enhancement of highly significant wildlife habitat ... for the protection 

of migratory waterfowl and other wildlife, including species known to be threatened with 

extinction, and to provide an opportunity for wildlife-oriented recreation and nature study ...” (86 

Stat. 399, dated June 30, 1972).

“... particular value in carrying out the national migratory bird management program” 16 U.S.C. 

667b (An Act Authorizing the Transfer of Certain Real Property for Wildlife, or other purposes).

“... to conserve (A) fish or wildlife which are listed as endangered species or threatened species.... 

or (B) plants ...” 16 U.S.C. 1534 (Endangered Species Act of 1973).

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

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

Service, in performing its activities and services. Such acceptance may be subject to the terms of 

any restrictive or affirmative covenant, or condition of servitude ...” 16 U.S.C. 742f (b)(1) (Fish and 

Wildlife Act of 1956).

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” (National Wildlife 

Refuge System Administration Act of 1966, as amended [16 U.S.C. 668dd-668ee]).

Description of Use: This compatibility determination is done as a review of the existing 

compatibility determination (1994) for selected outdoor recreation activities that include bicycling, 

hiking, jogging, walking, wildlife photography, and wildlife observation. It is also done in concert 

with the Don Edwards San Francisco Bay NWR Comprehensive Conservation Plan. This 

compatibility determination replaces the previous 1994 compatibility determination for selected 

outdoor recreation activities. 

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Wildlife observation and photography are two of six public uses (the other uses are hunting, 

fishing, environmental education, and interpretation) given priority on refuges as defined by 

Executive Order 12996 and the National Wildlife Refuge System Administration Act of 1966 as 

amended by the National Wildlife Refuge System Improvement Act of 1997 (Public Law 105-57).

Currently, wildlife observation and photography is permitted on foot (e.g., walking, hiking, and 

jogging) and bicycling on designated trails. The navigable and open waters of the Refuge are also 

open to boats. The Refuge has over 30 miles of trails (generally hard-packed gravel surface or 

paved) in the cities of Fremont, San Jose, East Palo Alto, Mountain View, Menlo Park, Sunnyvale, 

and Redwood City open during posted Refuge hours (which vary seasonally and by location). All 

motorized vehicles are prohibited on Refuge trails in order to protect ecologically sensitive areas. 

Bicycling is permitted on all roads and trails except the LaRiviere Marsh Trail. Information is 

posted on outdoor kiosks or available from staff. Additional wildlife viewing facilities will be 

constructed as funding is acquired. A raised boardwalk will be constructed at the FaberLaumeister site to enhance the existing trail area, which is currently a hard-packed gravel surface. 

A small percentage of Refuge trails are designated as a part of the Bay Trail1 or Bay Trail spur. 

Participating landowners of the Bay Trail set regulations for individual trail segments. 

Marshlands Road (Fremont) and the Moffett Bay Trail connector (Alviso) provide biking 

opportunities that are well used. 

Under the comprehensive conservation plan, at least one universally-accessible photo blind will be 

constructed to facilitate wildlife photography and a wildlife photography permit system will be 

created to improve access for wildlife photography (e.g., expanded hours, additional site access).

In addition to guided activities, the Refuge supports wildlife observation through a variety of selfguided activities. Maps and trail guides are available at interpretive kiosks, which are located near 

Refuge parking lots and trails, and at visitor facilities in Fremont and Alviso. A bird list is 

provided free of charge via printed brochure and by internet download. A variety of items are 

available for loan that aid in self-guided wildlife observation. These include: Children’s Discovery 

Packs, Family Birding Packs, adult birding kits, and binoculars. All are available for the public to 

borrow free of charge. A remote camera system will also be investigated for installation in a 

location that can provide virtual wildlife observation (e.g., colonial bird rookery, harbor seal 

pupping area, etc.). 

Many area organizations use the Refuge trails to conduct field trips for the purpose of wildlife 

observation and wildlife photography. Three chapters of the Audubon Society conduct their annual 

Christmas bird counts and breeding bird surveys at the Refuge. Ohlone Audubon covers the 

Alameda County area. Santa Clara Audubon covers the Alviso area. Sequoia Audubon covers Bair 

Island.

Availability of Resources: 

Funding and staffing exists to manage the existing opportunities for wildlife observation and 

photography on the Refuge. Additional staff and Service funding will be necessary to expand the 

wildlife observation and photography activities as prescribed in the CCP and as described in the 

following table. A visitor services information assistant and interpretive park ranger (position 

1 The Bay Trail is a planned recreational corridor that, when complete, will encircle San Francisco and San Pablo Bays 

with a continuous 500-mile network of bicycling and hiking trails. 

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shared with other programs) will be needed to conduct and enhance the additional guided and selfguided opportunities. An additional maintenance worker (position shared with other programs) 

will be needed to maintain and install new public use infrastructure. Replacement of signage, 

installation of additional signage and other outreach materials, improvements to the Tidelands 

Trail, construction of a boardwalk at the Faber-Laumeister site, installation of additional wildlife 

viewing facilities, installation of a photography blind, and a remote camera system will be needed 

to facilitate wildlife observation and photography. Grants and other funding sources will be sought 

as well.

Item One-Time Cost Annual Costs

Interpretive Park Ranger (0.5, GS0025-9)$39,500

Visitor Services Information 

Assistant (GS-0025-4/5)

$46,500

Maintenance Worker (0.25, WG4749-6/7/8)$16,250

Update old or outdated interpretive 

materials- information sheets and 

interpretive panels

$2,000

Improve Tidelands Trail Boardwalk 

(water bars)

$20,000

Construct boardwalk at FaberLaumeister site$400,000

Construct wildlife viewing facilities $100,000

Remote camera system $50,000

Photography blind $2,000

TOTAL $472,000 $164,750

Anticipated Impacts: 

Wildlife observation and photography will have positive benefits to the local community and 

visitors. Wildlife observation and photography provide opportunities to improve understanding 

and stewardship of habitat and wildlife resources. The uses will encourage connections between 

people and the outdoors, with the ultimate intent of protecting and conserving these natural 

resources.

Habitat

Wildlife observation and photography may result in minor disturbance to habitat such as trampling 

of vegetation, soil erosion, and soil compaction. Wildlife observation and photography is generally 

only allowed on designated levees and trails that have little to no vegetation since they are hardpacked gravel. Trails function as habitat and conduits for movement of plant species, including 

non-native, invasive plants (Dale and Weaver 1974). Refuge visitors provide a potential mechanism 

for non-native seed dispersion. Boaters conducting wildlife observation or photography also have 

the potential to crush vegetation if they exit their boats in areas that are not designated launch 

sites.

The photo permit system for wildlife photography may result in trampling of vegetation or 

dispersal of non-native seeds by allowing a limited number of individuals into areas closed to the 

public. These individuals could trample vegetation if they should wander off-trail. The number of 

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individuals in non-public areas is expected to be low (less than 12 people at a time in different areas 

of the Refuge). Access for this type of photography will be restricted with rules and further limited 

during sensitive breeding periods. Vehicular traffic associated with trail maintenance and Refuge 

management activities may introduce and spread non-native species onto the Refuge. Creation of 

additional infrastructure (e.g., wildlife viewing facilities, photography blinds) as well as 

infrastructure improvements could also result in displacement of habitat. However, such loss is 

expected to be minor based on avoidance, minimization, and other best management building 

practices. 

Wildlife

Large numbers of waterfowl, shorebirds, fish and other wildlife species use the Refuge for feeding, 

resting and in some cases, breeding. Several species, listed under the Federal Endangered Species 

Act as Threatened or Endangered, are present on the Refuge: vernal pool tadpole shrimp 

(Lepidurus packardi), steelhead (Oncorhynchus mykiss), California tiger salamander 

(Ambystoma californiense), California clapper rail (Rallus longirostris obsoletus), California least 

tern (Sterna antillarum browni), western snowy plover (Charadrius alexandrinus nivosus), salt 

marsh harvest mouse (Reithrodontomys r. raviventris), and Contra Costa goldfield (Lasthenia 

conjugens). 

Wildlife observation and photography may result in wildlife disturbance, eliciting responses 

including: 1) avoidance, 2) habituation, and 3) attraction (Knight and Cole 1991). 

Immediate responses by wildlife to recreational activity can range from behavioral changes 

including nest abandonment or change in food habits, physiological changes such as elevated heart 

rates due to flight, or even death (Knight and Cole 1991). The long term effects are more difficult 

to assess but may include altered behavior, vigor, productivity or death of individuals; altered 

population abundance, distribution, or demographics; and altered community species composition 

and interactions. 

Avoidance response may depend on a number of factors including the type, distance, movement 

pattern, speed, and duration of the disturbance, as well as the time of day, time of year, weather; 

and the animal’s access to food and cover, energy demands, and reproductive status (Knight and 

Cole 1991; Gabrielsen and Smith 1995). Human activities along wildlife observation trails can 

reduce foraging or even cause migratory birds to avoid foraging habitats adjacent to the trails 

(Klein 1993), especially when actions involve close proximity and/or fast-moving human activities 

(Burger 1981). Rapid movement by joggers is more disturbing to wildlife than slower moving 

hikers (Bennett and Zuelke 1999). However, joggers tend to spend less time in a particular area 

than pedestrians and are less likely to directly approach or otherwise disturb wildlife. Bicycling is 

not anticipated to disturb wildlife more than other public access, such as hiking, because riders are 

restricted to designated trails therefore making their movements more predictable for wildlife. 

Activities along trails tend to displace wildlife and can cause localized reduction in species richness 

and abundance (Riffell et al. 1996). In addition, nest predation tends to increase near more 

frequently utilized areas for songbirds (Miller et al. 1998), raptors (Glinski 1976), colonial nesting 

species (Buckley and Buckley 1976), and waterfowl (Boyle and Samson 1985). Knight and Cole 

(1991) suggest that sound may elicit a much milder response from wildlife if animals are visually 

buffered from the disturbance.

Boating to facilitate wildlife observation and photography may result in disturbance. A 2008 study 

of the behavioral response of harbor seals to boaters at Bair Island found that seal vigilance 

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increased as boats passed the haul-out, and as boats came closer to the seals. Though within ten 

minutes of the disappearance of the boats, the seals relaxed. During 70 percent of the boating 

events, seals did not flush, remaining at the haul-out. When flushing did occur, the seals almost 

always recovered within the large haul-out area. However, total seal numbers observed during 

days with multiple boats were lower than observed on days without boating activity (Fox 2008)

Wildlife observation and photography may also result in habituation by wildlife. Habituation is 

defined as a form of learning in which individuals stop responding to stimuli that carry no 

reinforcing consequences for the individuals that are exposed to them (Alcock 1993). A key factor 

for determining how wildlife would respond to disturbance is predictability. Often, when a use is 

predictable -- following a trail or boardwalk or at a viewing deck – wildlife will accept human 

presence (Oberbillig 2000). Gabrielsen and Smith (1995) suggest that most animals seem to have a 

greater defense response to humans moving unpredictably in the terrain than to humans following 

a distinct path. Wildlife may also be attracted to human presence. For example, wildlife may be 

converted to “beggars” lured by handouts (Knight and Temple 1995), and scavengers are attracted 

to road kills (Rosen and Lowe 1994).

Of the wildlife observation techniques, wildlife photographers tend to have the largest disturbance 

impacts (Klein 1993, Morton 1995, Dobb 1998). While wildlife observers frequently stop to view 

species, wildlife photographers are more likely to approach wildlife (Klein 1993). Other impacts 

include the potential for photographers to remain close to wildlife for extended periods of time, in 

an attempt to habituate the wildlife subject to their presence and the tendency of causal 

photographers with low-power lenses to get much closer to their subjects than other activities 

would require (Dobb 1998). This usually results in increased disturbance to wildlife and habitat, 

including trampling of vegetation as mentioned previously. Despite access to non-public areas, 

wildlife photographers are not expected to significantly impact wildlife because there will be 

restrictions on the number of individuals allowed access, rules on responsible wildlife watching, and 

prohibited access during sensitive breeding periods. Further, photography blinds will further 

lessen photographers’ impacts on wildlife and their habitat by reducing the frequency of 

unauthorized off-trail use, thus reducing the amount of vegetation trampled and the time spent in 

close proximity to the wildlife they are trying to photograph.

The activities associated with this use are not expected to significantly impact the ability of the 

Refuge to protect wildlife, diverse tidal marsh, seasonal wetland habitats and adjacent transitional 

uplands critical to the needs of migratory birds and listed species. The Refuge is already open to 

public access and also provides habitat for waterfowl, waterbirds, shorebirds and terns. 

Regulatory signage should also reduce disturbance to wildlife and damage to sensitive habitat

areas. Increasing public awareness is also expected to reduce the frequency and degree of adverse 

impacts resulting from this use. Outreach and education is critical for making visitors aware that 

their actions can have negative impacts on wildlife, and will increase the likelihood that visitors will 

abide by restrictions on their actions. For example, Klein (1993) demonstrated that visitors who 

spoke with refuge staff or volunteers were less likely to disturb birds.

Potential Conflicts between User Groups

Shared-use trails attract a variety of user groups who often have conflicting needs. People with 

disabilities may be particularly affected if they do not have the ability to quickly detect or react to 

hazards or sudden changes in the environment.

Bicycles using the same trail as pedestrians may present a safety hazard to visitors. If the number 

C-45
of trail users increases as predicted, the potential for accidents or user group conflicts may also 

increase. However, the proposed trails meet Federal Highway Administration standards for 

shared use path design (Federal Highway Administration 2001) and should be able to 

accommodate increased use. Although user groups are not physically separated, the trails provide 

sufficient tread width, grade (essentially flat), viewing distance, clearance, and a firm and stable 

surface for safe, shared use by pedestrians and joggers, as well as bicycle riders traveling at a safe 

speed.

Measures to reduce potential conflicts between user groups would include providing information at 

the trailhead, Visitor’s Center, EEC, and in the Refuge’s brochure that clearly indicates permitted 

users and rules of conduct. Providing signs that clearly indicate which users have the right of way 

would help mitigate conflict (Federal Highway Administration 2001). Trail etiquette signing would 

clearly state that bicycles should give an audible warning before passing other trail users.

Potential conflict with other public use such as hunting, and interpretation will be minimized by 

using trail head signs and other media to inform the various users about current public uses.

Public Review and Comment: 

Public review and comments were solicited in conjunction with distribution of the Draft CCP/EA 

for Don Edwards San Francisco Bay NWR, released in May 2012. One commenter requested that 

further analysis on boating impacts in the CD. Information on boating impacts was added to the 

“Anticipated Impacts” section.

Determination: 

_______ Use is Not Compatible

___X___ Use is Compatible with Stipulations

The following stipulations are required to ensure compatibility: 

• Staff, brochures, and signage and other informational material such as websites will inform 

visitors of proper etiquette for wildlife observation and photography (including methods for 

proper bicycling).

• Collection of plants, animals, and other specimens, debris, or artifacts by visitors is strictly 

prohibited.

• Maintenance and construction activities related to Refuge roads, trails, and other visitor 

infrastructure would occur during specific periods of the year to avoid disturbance or 

impacts to birds during breeding season.

• Infrastructure to facilitate these public uses will be designed to minimize impacts to wildlife 

though proper location, design and building material.

• Most public uses will be confined to trail surfaces and the public will not be allowed to enter 

adjacent habitat or closed areas.

C-46
• No bicycling is permitted on La Riviere Marsh Trail.

• No motorized vehicles or skateboards are permitted on Refuge trails.

• Dog walking is prohibited on the Refuge except on the Refuge’s Tidelands Trail. This trail 

is closely monitored by Refuge staff and volunteers due to its proximity to Refuge staff 

offices. Dogs will be permitted on this trail only if they are on a six-foot or shorter leash 

and are under the direct control of the dog walker. The dog walker must pick up and 

properly dispose of their dog’s waste. Monitoring will include user estimates, compliance 

with regulations, impact on wildlife and conflicts between other user groups and dog 

walkers. If impacts to wildlife or their habitats are identified that cannot be effectively 

mitigated, dog walking may be prohibited on this trail as well.

• Wildlife photography will be permitted in areas closed to the public under a Special Use 

Permit. There will be restrictions on number of individuals, rules on responsible wildlife 

watching, and prohibited access during sensitive breeding periods.

• Buffers will be maintained around existing trails and viewing platforms to protect nesting 

and roosting birds. Buffers will be included in the design of any new viewing platforms, 

boardwalks, or other relevant infrastructure.

• Refuge law enforcement will ensure compliance with regulations and area closures, and will 

discourage vandalism and off trail activity.

• Several stipulations would minimize the potential for impacts from non-native species 

invasion. First, public uses would be restricted to level surfaces, which would reduce 

spread of non-native seed from the levees and boardwalks onto the Refuge. Second, 

invasive plants that germinate on the levee top and sides would be treated with herbicide. 

Third, monitoring and surveillance of invasive species would increase, reducing the 

potential for new invasive species to become established on the trail and spread into the 

Refuge.

• Potential conflict with other public use such as waterfowl hunting, environmental education,

and interpretation activities will be minimized by using trail head signs and other media to 

inform the various users about current public uses; if necessary, activities will be separated 

in time and place.

• Trails, platforms, blinds and other wildlife observation and photography facilities will be 

subject to seasonal closures during bird breeding season (April – August) if deemed 

necessary, based on the species needs and the results of adaptive management studies.

• Trails will only be open for wildlife observation and photography during posted Refuge 

hours (generally daylight hours).

• No organized races will be permitted on Refuge trails.

Justification: Wildlife observation and wildlife photography are Priority Public Uses as defined by 

the NWRS Administration Act of 1966, as amended by the NWRS Improvement Act of 1997 

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(Public Law 105-57), and if compatible, are to receive enhanced consideration over other general 

public uses. These uses are supportive of the Refuge’s purposes and the mission of the NWRS. 

Wildlife observation and photography would provide an excellent forum for allowing public access 

and increasing public understanding and appreciation of Refuge resources. The Refuge is one of 

the few areas in the urban South San Francisco Bay to be able to offer these uses. It is one of the 

only locations with access to former commercial salt ponds and the open bay that is managed for 

wildlife and can offer these wildlife oriented activities in these unique habitats. 

Potential for wildlife disturbance is expected to be minimal. Restricting the disturbance to an 

established trail with appropriate set-back distances (buffers) would increase predictability of 

public use patterns on the Refuge, allowing wildlife to habituate to non-threatening activities. 

Consolidating compatible recreational activities to designated trails, located at the edge of the 

Refuge habitat boundary, reduces habitat fragmentation, thereby maintaining a core “sanctuary 

area” of the Refuge for more sensitive species.

The stipulations outlined above are expected to minimize potential impacts relative to 

wildlife/human interactions. In particular, the adaptive management studies will determine the 

exact nature of the public use impacts on the Refuge’s wildlife and allow Refuge managers to 

adjust public use to further minimize wildlife impacts or discontinue those activities that are 

unacceptable. The proposed activities will not materially interfere or detract from the fulfillment 

of the NWRS Mission or the purposes of the Refuge.

Mandatory Reevaluation Date (provide month and year):

____X____ Mandatory 15-Year Reevaluation Date (for priority public uses)

__________ Mandatory 10-Year Reevaluation Date (for all uses other than priority 

public uses)

NEPA Compliance for Refuge Use Decision (check one below):

Conducted with Comprehensive Conservation Plan

______Categorical Exclusion without Environmental Action Statement

______Categorical Exclusion and Environmental Action Statement

 X Environmental Assessment and Finding of No Significant Impact

 Environmental Impact Statement and Record of Decision

References Cited:

Alcock, J. 1993. Animal behavior: an evolutionary approach. Fifth ed. Sinauer Assoc., Sunderland, 

MA. 625pp.

Bennett, K.A. and E. Zuelke. 1999. The effects of recreation on birds: a literature review. 

Delaware Natural Heritage Program, Smyrna, DE.

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Boyle, S. A. and F. B. Samson. 1985. Effects of nonconsumptive recreation on wildlife: a review. 

Wildlife Society Bulletin 13:110-116.

Buckley, P.A. and F.G. Buckley. 1976. Guidelines for protection and management of colonially 

nesting waterbirds. North Atlantic Regional Office, National Park Service, Boston, MA. 52pp.

Burger, J. 1981. The effect of human activity on birds at a coastal bay. Biol. Cons. 21:231-241.

Dale, D. and T. Weaver. 1974. Trampling effects on vegetation of the trail corridors of north 

Rocky Mountain forests. J. Applied Ecology 11:767-772.

Dobb, E. 1998. Reality check: the debate behind the lens. Audubon: Jan.-Feb.

Federal Highway Administration. 2001. Designing sidewalks and trails for access, Part II, best 

practices design guide. U.S. Department of Transportation. Available on-line at: 

http://www.fhwa.dot.gov/environment/sidewalk2/ {last accessed on August 3, 2007}. 

Fox, K. S. 2008. Harbor seal behavioral reponse to boaters at Bair Island refuge. Master's 

Theses. Paper 3591. http://scholarworks.sjsu.edu/etd_theses/3591.

Gabrielsen, G.W. and E.N. Smith. 1995. Physiological responses of wildlife to disturbance. Pages 

95-107 in R.L. Knight and K.J. Gutzwiller (eds.), Wildlife and Recreationists: coexistence 

through management and research. Island Press, Washington, D. C. 372pp.

Glinski, R.L. 1976. Birdwatching Etiquette: the need for a developing philosophy. Am. Bird 

30(3):655-657.

Klein, M.L. 1993. Waterbird behavioral response to human disturbances. Wildlife Society 

Bulletin. 21:31-39.

Knight, R. L. and D. N. Cole. 1991. Effects of recreational activity on wildlife in wildlands in 

Transactions of the North American Wildlife and Natural Resources Conference. 56:238-247.

Knight, R.L. and D.N. Cole. 1995. Wildlife responses to recreationists. Pages 71-79 in R.L. 

Knight and K.J. Gutzwiller, eds. Wildlife and Recreationists: coexistence through 

management and research. Island Press, Washington, D.C. 372 pp.

Knight, R.L. and S.A. Temple. 1995. Origin of wildlife responses to recreationists. Pages 81-91 in 

R.L. Knight and K. J. Gutzwiller (eds.), Wildlife and Recreationists: coexistence through 

management and research. Island Press, Washington, DC.

Miller, S.G., R.L. Knight, and C.K. Miller. 1998. Influence of recreational trails on breeding bird 

communities. Ecological Applic. 8:162-169.

Morton, J.M. 1995. Management of human disturbance and its effects on waterfowl. Page F59-

F86 in W.R. Whitman, T. Strange, L. Widjeskog, R. Whittemore, P. Kehoe, and L. Roberts 

(eds.). Waterfowl habitat restoration, enhancement and management in the Atlantic Flyway. 

Third Ed. Environmental manage. Comm., Atlantic Flyway Council Tech. Sect., and Delaware 

Div. Fish and Wildlife Dover, DE 1114pp.

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Oberbillig, D.R. 2000. Providing positive wildlife viewing experiences. Deborah Richie 

Communications, Missoula, MT.

Riffell, S.K., K.J. Gutzwiller, and S.H. Anderson. 1996. Does repeated human intrusion cause 

cumulative declines in avian richness and abundance? Ecol. Appli. 6(2): 492-505.

Rosen, P.C. and C.H. Lowe. 1994. Highway mortality of snakes in the Sonoran Desert of southern 

Arizona. Biol. Conserv. 68:143-148.

U.S. 16 U.S. C. 668dd-ee. 1966. National Wildlife Refuge System Administration Act.

U.S. Public Law 105-57. 1997. National Wildlife Refuge System Improvement Act. 

C-50

Compatibility Determination for Environmental Education and Interpretation

Don Edwards San Francisco Bay National Wildlife Refuge

Use: Environmental Education and Interpretation 

Station Name: Don Edwards San Francisco Bay National Wildlife Refuge, Alameda, Santa Clara 

and San Mateo Counties, California

Date Established: June 30, 1972

 

Establishing and Acquisition Authorities: 

86 Stat. 399, dated June 30, 1972

An Act Authorizing the Transfer of Certain Real Property for Wildlife, or other purposes (16 

U.S.C. 667b)

Endangered Species Act of 1973 (16 U.S.C. 1534) 

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

 

Refuge Purpose(s): 

“... for the preservation and enhancement of highly significant wildlife habitat ... for the protection 

of migratory waterfowl and other wildlife, including species known to be threatened with 

extinction, and to provide an opportunity for wildlife-oriented recreation and nature study ...” (86 

Stat. 399, dated June 30, 1972).

“... particular value in carrying out the national migratory bird management program” 16 U.S.C. 

667b (An Act Authorizing the Transfer of Certain Real Property for Wildlife, or other purposes).

“... to conserve (A) fish or wildlife which are listed as endangered species or threatened species.... 

or (B) plants ...” 16 U.S.C. 1534 (Endangered Species Act of 1973).

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

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

Service, in performing its activities and services. Such acceptance may be subject to the terms of 

any restrictive or affirmative covenant, or condition of servitude ...” 16 U.S.C. 742f (b)(1) (Fish and 

Wildlife Act of 1956).

National Wildlife Refuge System Mission: The mission of the National Wildlife Refuge System 

(NWRS) 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” 

(NWRS Administration Act of 1966, as amended [16 U.S.C. 668dd-668ee]).

Description of Use: This compatibility determination is done in concert with the Don Edwards 

San Francisco Bay NWR Comprehensive Conservation Plan. Environmental education and 

interpretation are two of six public uses (the other uses are hunting, fishing, wildlife observation, 

C-52
C-53
and photography) given priority on refuges as defined by Executive Order 12996 and the National 

Wildlife Refuge System Administration Act of 1966 as amended by the National Wildlife Refuge 

System Improvement Act of 1997 (Public Law 105-57). 

Environmental Education

The Refuge was established to provide opportunities for “nature study”. Because environmental 

education is part of the Refuge purposes, it is a high priority for the Refuge. To this end, the 

Environmental Education Center (EEC) was built in 1979 to facilitate environmental education. 

The Environmental Education Program serves over 10,000 students annually, providing 

supporting materials for other educators along with curriculum-based field trips and classroom 

presentations. Known for developing high quality, innovative instructional models and 

programmatic materials, the Refuge is a leader in the environmental education field and also 

provides trainings and resources for other educators in the U.S. Fish and Wildlife Service (Service) 

and the national environmental education community.

The majority of field trips and educational programs take place at the headquarters site in 

Fremont (hereafter referred as headquarters) and the EEC, which is located in Alviso. As 

prescribed in the comprehensive conservation plan (CCP), the EEC will be remodeled to 

accommodate additional programs as well as meet LEED certification requirements. School 

districts and students from all over the Bay Area participate in field trip programs. Additional 

programs occur on the Faber-Laumeister sub-unit of the Refuge in East Palo Alto. Several 

funding partnerships allow us to provide a variety of educational programs. Some of the partners 

include the City of San Jose, Santa Clara Valley Urban Runoff Pollution Prevention Program, and 

San Francisco Bay Wildlife Society. To facilitate environmental education in the future, a LEEDcertified visitor services complex will be constructed at headquarters, as prescribed in the CCP.

Some of the many environmental education programs taking place or planned for the future as 

prescribed in the CCP at the Refuge are described below:

Wetland Round-up

Wetland Round-up is an educator-led field trip program designed for grades K-6. It is the oldest 

and largest environmental education program on the Refuge. Conducted both at the EEC and the 

headquarters, this program brings schoolchildren out to the Refuge to learn about tidal marsh, 

endangered species, native wildlife, and the importance of their habitat. 

All activities are correlated to State of California Education Standards. Teachers are required to 

attend a teacher orientation once every 2 years. It is recommended that parents also attend 

training. Parents lead the hands-on activities by using a “Do, Read, Ask” teaching script. The 

program is offered 3-4 times per week October-December and March-May. The Salt Marsh 

Manual, an educators’ guide, is provided to teachers to help plan their field trip. The Salt Marsh 

Manual presents all the activity scripts, pre- and post-visit activities, background information, 

guidance on planning the field trip, and other resources. Educator training and environmental 

education resources will be improved for use by partners and educators.

To support this program, the Refuge provides a video lending library for teachers. The Salt Marsh 

Manual will be translated to Spanish. Additional partners will be sought to host this program (e.g., 

Girl Scouts).

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Slow the Flow

The Slow the Flow program seeks to inform participants about water pollution and consumption 

habits as they relate to habitat protection and endangered species conservation. This program 

connects the Slow the Flow messages to visitors and students through classroom presentations, 

field trips, interpretive programs, and outreach events (e.g., Bird Fest, Spooky Slough). The field 

trip program covers 5th grade through college, an age group not covered by Wetland Round-up. 

This program provides over 5,000 visitor experiences per year. Under the CCP, the Refuge staff 

plan to increase capacity for joint Water Pollution Control Plant/EEC tours and improve the Slow 

the Flow curriculum.

Restoration Education

The restoration education program is a service learning program (a combination of community 

service and classroom curriculum) which focuses on habitat restoration. Each year, over 300 

students from a local high school participate in wetland studies and service learning at the 

headquarters. The Habitat Heroes Summer Camp program also includes restoration education at 

the headquarters. 

In Alviso, local elementary school, middle school, and college students have participated in service 

learning programs since 2006, and in 2010 a restoration education field trip program was piloted 

for elementary and college-aged students. This program is continually being modified and 

improved. We will develop and expand the audience for this program to neighboring communities 

over the life of the CCP. Habitat restoration programs will be developed for Warm Springs, 

Mayhew’s Landing, Alviso, Fremont, and East Palo Alto.

The restoration education program also serves non-school based audiences. The restoration 

education program in Alviso utilizes a Native Plant Demonstration Garden. The garden is used by 

the EEC staff to teach children and adults about planting techniques and native plant species that 

can be used to provide habitat for a variety of wildlife in their home garden. Education programs 

about native plants and gardening with native plants are offered quarterly.

A different approach to restoration education has been used on the Faber-Laumeister sub-unit of 

the Refuge located in East Palo Alto. A summer employment program for local high school 

students was started in 2010, using Youth Conservation Corps funding, to engage young people in 

habitat restoration education. In 2010, we also started providing service learning opportunities for 

school clubs and after school programs in East Palo Alto and vicinity. These opportunities will be 

expanded to include school field trips.

Summer Camp Programs

The Refuge hosts two free summer day camps for youth: Marsh-In Summer Day Camp and 

Habitat Heroes Camp. Together, these camps provide opportunities for children in 1st-12th grade 

to learn more about the Refuge, ecology, and conservation. The program is tiered so that youth 

continue to benefit from the experience as they grow. 

The Marsh-In Summer Day Camp, established in 1980 and held at the EEC, is designed for grades 

1-6. For one week, campers participate in hands-on activities such as crafts, games, and nature 

walks, designed to connect children to nature and to teach about wildlife, plants, habitats, and 

natural resource conservation. On the last night of camp, campers in grades 4-6 spend the night 

under the stars at the EEC. 

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The Habitat Heroes camp at headquarters began in 2007 and is designed for grades 7-12. Each 

year through the Habitat Heroes program, a dozen teens develop leadership and team-building 

skills by participating in trust and problem solving activities. Most of the participants are former 

Marsh-In Summer Day Camp attendees. Service projects are included throughout the week. In 

addition, the teens pledge future service to the Refuge and practice their new skills as junior 

counselors at the Marsh-In Summer Day Camp. Habitat Heroes introduces a new generation of 

leaders to our refuge and develops them as dedicated stewards. Many past participants in the 

Habitat Heroes program continue to volunteer at the Marsh-In Summer Day Camp and also at 

other Refuge events to provide opportunities for others to learn about conservation and the 

Refuge. The Habitat Heroes Program will be expanded to include enrichment activities throughout 

the year.

Climate change

The environmental education program will be expanded to include a climate change curriculum and 

the effects of climate change on Refuge resources. The future LEED-certified visitor service 

complex and EEC will be used as demonstration tools to encourage others to implement LEED 

features.

Scout Programs

Programs tailored to meet badge requirements for the Girl Scouts and Boy Scouts of America are 

offered at the EEC and at the headquarters. Activities are presented intermittently depending 

upon the expertise and availability of EEC staff. At the EEC, Webelos, Junior Girl Scout Badge, 

and Brownie Eco-Explorer patch programs are offered. At the headquarters site, Webelos 

programs are offered. Discovery Packs for self-guided activities will be redesigned to improve the 

Program.

Santa Clara Valley Urban Runoff Pollution Prevention Program

The Santa Clara Valley Urban Runoff Pollution Prevention Program provides grant funding for a 

full-time interpretive specialist and a stipend for a part-time intern to administer the Watershed 

Watchers program at the EEC. The program presents a range of interpretive programs. All 

programs revolve around a common theme: Our Role in Preventing Urban Runoff Pollution. Scout 

packs and troops, Lyceum groups, after-school child care centers, universities, and senior centers 

all participated in tours of the wetlands at the Refuge. Through discussions and activities, 

participants learned about the Refuge’s unique habitats, the diverse life dependent on these 

habitats, and the protection of wildlife through prevention of urban runoff pollution from storm 

drains. This program hosts several popular special events at the Refuge including the South Bay 

Bird Festival, Shark Day, and Spooky Slough. The Refuge relies directly on this funding and 

staffing to keep the EEC open on Saturdays.

Interpretation: 

The Refuge provides an extensive interpretive program that offers guided programs, self-guided 

opportunities, and special annual events. The CCP calls for the EEC to be remodeled to provide 

better interpretive exhibits. The CCP also identifies that a visitor services complex will be 

constructed at the headquarters to house interpretive exhibits and activities.

Guided Programs

Refuge staff and volunteers offer over 200 guided interpretive programs annually. The majority of 

programs are given at the headquarters and the EEC, though programs are regularly offered at 

other Refuge and partner sites. These programs are conducted on the Refuge at the following 

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locations: Ravenswood sub-unit, Stevens Creek East Trailhead, and the Dumbarton Bridge fishing 

pier.

Programs cover a variety of natural and cultural history topics. A sample of the topics presented 

includes: bird watching, historical use of local marshlands, wetlands restoration, salt marsh 

ecology, nature photography, native plants and animals, star gazing, and pollution prevention. 

Conducted programs include walks and hikes, bike and van tours, fishing clinics, planting parties, 

habitat restoration clean-up events, photography and sketching workshops, festivals and special 

events. Under the CCP, the interpretive programs will be updated with at least two new 

interpretive opportunities annually, such as outdoor recreation-based activities (e.g., yoga 

program, bicycling tours). A water-based guided program such as canoe or kayak tours will be 

researched and offered as feasible. The CCP calls for interpretation to be expanded at the Warm 

Springs sub-unit with at least four tours during the vernal pool flowering season and interpretive 

materials (e.g., panels and information sheets). Outdated or old interpretive materials such as 

panels and information sheets will be replaced. The EEC will also be updated to provide visitor 

contact or information services on the weekends.

Tours are provided for specific program areas including the South Bay Salt Pond Restoration 

Project (SBSPRP), Watershed Watchers, and garden tours. Private interpretive programs are 

also offered through special request. Audubon chapters, scout troops, community groups, senior 

centers, teachers’ associations, and college classes are just a few groups which take advantage of 

this opportunity. 

The interpretive program for the SBSPRP focuses on wetlands restoration and wildlife. Elements 

of the interpretive program for the SBSPRP include guided public programs, development of 

interpretive media and displays, and creation of a docent program. Guided public programs are 

offered once per week at a minimum and often include birding classes, van and bicycle tours of the 

managed ponds, hikes, and talks. Van tours of the SBSPRP allow visitors with lower mobility get 

out into the pond landscape. Private tours and programs for special groups, such as university 

classes and media outlets, are also conducted by reservation. 

Garden tours of the EEC’s habitat gardens and introductions to chemical-free gardening 

techniques are also conducted. The annual Native Plant Nursery Open House during National 

Wildlife Refuge Week offers techniques on how to garden with native plants for wildlife.

Self-Guided Interpretive Opportunities

The Refuge provides visitors a range of self-guided opportunities to help them connect with Refuge 

resources. Interpretative displays and other information signs in Alviso are presented in English

and Spanish. Another self-guided interpretive program using Refuge-designated geocaches helps 

to promote connections between the Refuge and people through current technology.

Old or outdated interpretive signs on the Refuge are being and will continue to be updated over the 

life of the CCP to help facilitate self-guided walks. Over 30 new signs have been created and 

installed since 2009. They are found along the Tidelands trail (Fremont), the Marsh View, New 

Chicago Marsh, Mallard Slough and Moffet Bay Trail trails (Alviso) and the SF2 trail 

(Ravenswood). The Tidelands Trail in Fremont is registered as a National Recreation Trail in the 

National Trails System and a spur of the San Francisco Bay Trail. Two new audio tours will also 

be created to facilitate a future self-guided auto tour route at the headquarters. A nature 

exploration area will be developed at the headquarters to promote the Service’s “Children in 

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Nature” Initiative and the NWRS Vision.

New interpretive exhibits at the Visitor Contact Station (VCS) (2010) and the EEC (2010-11) also 

provide opportunities for self-guided discovery of refuge resources. The VCS exhibits introduce 

the visitor to the San Francisco Bay NWR Complex (including the Don Edwards National Wildlife 

Refuge), refuge wildlife, and wetlands restoration efforts. The EEC exhibits illustrates and 

interprets five periods of human history along the Bay shoreline. 

A Refuge program uses staff-designated geocache sites in appropriate areas of the Refuge to 

facilitate interpretive opportunities. Participants use a Global Positioning System (GPS) receiver 

or other navigational techniques to hide and seek containers (called “geocaches” or “caches”) 

anywhere in the world. Although traditional geocaching is prohibited on Refuge lands, an 

alternate program has been made available to gadget lovers. The Refuge has placed coordinates or 

“caches” in compatible locations with information about the Refuge in order to connect people with 

nature through current technology. This activity encourages the public to explore various parts of 

the Refuge in the South and East Bay and learn more about Refuge objectives. 

Special Events

Special events are also held on the Refuge as vehicles for interpretation. Currently special events 

are described below. Ten, on-site, annual special events will be held annually within the life of the 

CCP. Currently, these include the following:

Earth Day

The annual Earth Day Clean-Up takes place at the Ravenswood Unit in Menlo Park. Staff and 

volunteers lead participants on the trail picking up trash. Working alongside staff gives 

participants a unique perspective on management issues and wildlife that they might not otherwise 

receive.

Endangered Species Poster Contest/Endangered Species Day

The Endangered Species Poster Contest has been in existence for 28 years and is co-sponsored by 

the San Francisco Bay Wildlife Society. The contest is open to schools with grades K-6 in Newark, 

Union City, Fremont, and East Palo Alto.

South Bay Bird Fest

The South Bay Bird Fest is hosted by the Santa Clara Valley Urban Runoff Pollution Prevention 

Program (SCVURPPP) at the EEC to celebrate International Migratory Bird Day. The Santa 

Clara Valley Audubon Society, San Francisco Bay Bird Observatory, and San Francisco Bay 

Wildlife Society collaborate with Refuge staff and SCVURPPP staff to hold this very popular 

interpretive event. In 2010, over 300 participants took part in its bird walks, migratory songbird 

gardening workshops, and live bird show.

Coastal Clean-Up Day

The Refuge hosts a Coastal Cleanup in Fremont each September in coordination with the Alameda 

County Coast Cleanup Commission. In 2010, well over 150 volunteers participated in the cleanup 

along Shoreline Trail.

National Wildlife Refuge Week

The Refuge hosts a range of onsite activities and events in celebration of National Wildlife Refuge 

Week. The Connections to Pier Fishing event and a native plant sale are annual offerings. In 

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addition, each year a new event is offered to help encourage participation from returning visitors. 

Events have ranged from Open Houses to drawing and photography demonstrations to 

competitive games and always focus on refuge objectives, wildlife, natural history, and/or 

conservation. 

Availability of Resources: 

Funding and staffing is available to manage the existing environmental education and 

interpretation for the Refuge. Additional staff and Service funding will be necessary to expand the 

environmental education and interpretation programs as prescribed in the CCP as described in the 

following table. A visitor services information assistant and interpretive park ranger (position 

shared with other programs) will be needed to conduct and enhance the additional guided and selfguided opportunities. Two additional environmental education specialists, one with bilingual 

background, will be needed for the expanded environmental education program. An additional 

maintenance worker (position shared with other programs) will be needed to maintain and install 

new public use infrastructure. A visitor center complex at the headquarters, update of the EEC, 

replacement of interpretive materials, and materials for conducting new programs will be needed 

to expand environmental education and interpretation. Construction of a nature exploration area 

will encourage children to explore the outdoors and support the Service’s Children in Nature 

initiative. Grants and other funding sources will be sought as well.

Item One-Time Cost Annual Costs

Visitor Services Information 

Assistant (GS-0025-4/5)

$46,500

Interpretive Park Ranger (0.5, GS0025-9)$39,500

Bilingual Environmental Education 

Specialist (GS-1701-9)

$79,000

Environmental Education Specialist* 

(GS-1701-9)

$79,000

Maintenance Worker (0.25, WG4749-6/7/8)$16,250

Visitor Center Complex $7,000,000

New interpretive programs $200

10 special events $1,000

Update old or outdated interpretive 

materials

$2,000

Update EEC $3,500,000

Climate change/LEED curriculum $10,000 $500

New teacher and student resources $5,000 $1,000

New training materials for educators $5,000 $1,000

Additional Science Nights $1,000 $500

Additional Restoration Education 

program sites

$10,000 $3,000

Watershed study and water 

conservation education program

$10,000 $5,000

Contract for Spanish translation $15,000 $1,000

Additional Habitat Heroes program $300

4 Discovery packs $500 $300

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Nature exploration area $85,000 $2,000

Summer Camp $900

TOTAL $14,641,500 $278,950

*This position would be needed if grant funding was eliminated for the Slow the Flow Integrated Field Trip Program and Santa Clara 

Valley Urban Runoff Pollution Program.

Anticipated Impacts: 

Habitat

Environmental education and interpretation activities may result in minor disturbance to habitat 

such as trampling of vegetation, soil erosion, and soil compaction. Refuge visitors also provide a 

potential mechanism for non-native seed dispersion. Trails function as conduits for movement of 

plant species, including non-native, invasive plants (Dale and Weaver 1974). Vehicular traffic

associated with trail maintenance and Refuge management activities may introduce and spread 

non-native species onto the Refuge. Creation of additional infrastructure (e.g., wildlife viewing 

facilities, interpretive panels) as well as infrastructure improvements would also result in impacts 

to wildlife habitats or displacement of wildlife species. However, this construction is expected to be 

minor given the size of the Refuge and by avoiding or minimizing intrusion into sensitive wildlife 

habitat. Also, all these activities take place primarily on the Refuge’s trail system or designated 

public use areas which have little to no vegetation since they are hard-packed dirt. Also, guided 

programs would be supervised by Refuge staff, volunteers, or partners. Information on reducing 

impacts to habitat would be provided via website, visitor center, and staff to visitors enjoying selfguided interpretation opportunities.

Wildlife

Trail based environmental education and interpretation events can cause immediate responses by 

wildlife. These can range from behavioral changes including nest abandonment or change in food 

habits, physiological changes such as elevated heart rates due to flight, or even death (Knight and 

Cole 1991). The long term effects are more difficult to assess but may include altered behavior, 

vigor, productivity or death of individuals; altered population abundance, distribution, or 

demographics; and altered community species composition and interactions. According to Knight 

and Cole (1991), there are three wildlife responses to human disturbance: 1) avoidance; 2) 

habituation; and 3) attraction. 

The magnitude of the avoidance response may depend on a number of factors including the type, 

distance, movement pattern, speed, and duration of the disturbance, as well as the time of day, time 

of year, weather; and the animal’s access to food and cover, energy demands, and reproductive 

status (Knight and Cole 1991; Gabrielsen and Smith 1995). Knight and Cole (1991) suggest that 

sound may elicit a much milder response from wildlife if animals are visually buffered from the 

disturbance.

Habituation is defined as a form of learning in which individuals stop responding to stimuli that 

carry no reinforcing consequences for the individuals that are exposed to them (Alcock 1993). A 

key factor for determining how wildlife would respond to disturbance is predictability. Often, when 

a use is predictable -- following a trail or boardwalk or at a viewing deck – wildlife will accept 

human presence (Oberbillig 2000). Gabrielsen and Smith (1995) suggest that most animals seem to 

have a greater defense response to humans moving unpredictably in the terrain than to humans 

following a distinct path. 

Results of local studies indicate that non-motorized trail use, on raised levees, tangential to tidal 

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mudflat habitat does not have a significant overall effect on the numbers, species richness, or 

behavior of foraging shorebirds. At the Shoreline site, waterbird abundance and species richness 

were higher near trail sites than at control sites (Trulio and Sokale 2007). However, the results of 

this study are not applicable to other waterbird guilds, especially waterfowl. 

Environmental education and interpretive programs also helps make visitors aware that their 

actions can have negative impacts on birds, and will increase the likelihood that visitors will abide 

by restrictions on their actions. For example, Klein (1993) demonstrated that visitors who had 

spoken with refuge staff or volunteers were less likely to disturb birds. Increased surveillance and 

imposed fines may also help reduce visitor caused disturbance (Knight and Gutzwiller 1995). 

Monitoring is recommended to adjust management techniques over time, particularly because it is 

often difficult to generalize about the impacts of specific types of recreation in different 

environments. Local and site-specific knowledge is necessary to determine effects on birds and to 

develop effective management strategies (Hockin et al. 1992; Klein et al. 1995; Hill et al. 1997). 

Informed management decisions coupled with sufficient public education could do much to mitigate 

disturbance effects of wildlife-dependent recreations (Purdy et al. 1987).

Environmental education and interpretation activities generally support the Refuge’s purposes 

and impacts can largely be minimized (Goff et al. 1988). The minor resource impacts attributed to 

these activities are generally outweighed by the benefits gained by educating the public about 

refuge resources. Environmental education is a public use management tool used to develop a 

resource protection ethic within society. While it targets school age children, it is not limited to 

this group. This tool allows us to educate refuge visitors about endangered and threatened species 

management, wildlife management and ecological principles and communities. A secondary benefit 

of environmental education is that it instills an ‘ownership’ or ‘stewardship’ ethic in visitors and 

most likely reduces vandalism, littering and poaching. It also strengthens Service visibility in the 

local community.

The disturbance by environmental education activities is considered to be of minimal impact 

because: (1) the total number of students permitted through the reservation

system will be limited; (2) students and teachers will be instructed in etiquette while on the Refuge 

and the best ways to view wildlife with minimal disturbance; (3) education groups will be required 

to have a sufficient number of adults to supervise the group; and (4) activity areas will located away 

from sensitive wildlife habitat.

Overall, increased visitation resulting from the environmental education and interpretation 

program may impact sensitive species and their habitats. However, these effects would be 

monitored and managed to ensure that impacts to sensitive species and their habitats do not reach 

significant levels. 

Shared-use trails attract a variety of user groups who often have conflicting needs. People with 

disabilities may be particularly affected by trail conflicts if they do not have the ability to quickly 

detect or react to hazards or sudden changes in the environment. Measures to reduce potential 

conflicts between user groups would include providing information at the trailhead, Visitor Center, 

and in the Refuge’s brochures that clearly indicates permitted users and rules of conduct. 

Providing signs that clearly indicate which users have the right of way would help reduce conflict 

(Federal Highway Administration 2001). Potential conflict with other public uses such as 

waterfowl hunting, wildlife observation, and photography will be minimized by using trail head 

signs and other media to inform the various users about current public uses. 

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Public Review and Comment: 

Public review and comments were solicited in conjunction with distribution of the Draft CCP/EA 

for Don Edwards San Francisco Bay NWR, released in May 2012. No comments were made 

directly in regard to this compatibility determination.

Determination: 

_______ Use is Not Compatible

___X___ Use is Compatible with Stipulations

The following stipulations are required to ensure compatibility: 

• Maintenance of trails and construction of new proposed viewing platforms, boardwalks, and 

environmental education and interpretation facilities (e.g. visitor center and updated EEC) 

would occur during specific periods of the year to avoid disturbance or impacts to birds 

during breeding season;

• The proposed viewing platforms, boardwalks, and environmental education and 

interpretation facilities (e.g. visitor center and updated EEC) will be designed to minimize 

impacts to wildlife though proper location, design and building material;

• Raised platforms will be constructed to view wildlife allowing for a superior wildlife viewing 

experience while reducing disturbance levels to wildlife and habitat by concentrating 

visitors in one location;

• Environmental education and interpretation will be confined generally to trail surfaces and 

the public will not be allowed to enter adjacent habitat or closed areas;

• Buffers will be maintained around trails and viewing platforms to protect nesting and 

roosting birds;

• Information will be provided at trailheads, at the VCS and EEC, in refuge publications and 

flyers, on kiosks, and through interpretative programs about permitted uses, rules of 

conduct, and the effects of human impacts on habitat and wildlife resources. The Refuge 

will explain how wildlife lives and how the visiting public can avoid negative impacts to 

wildlife;

• Periodic law enforcement will ensure compliance with regulations and area closures, and 

will discourage vandalism and off-trail activity;

• Potential impacts from the public spreading non-native seeds would be minimized by: (1) 

restricting public uses to level surfaces, which would tend to prevent the transportation of 

non-native seed from the levees and boardwalks into other habitats, such as wetlands, 

through wind and water; (2) invasive plants that germinate on the levee top and sides would 

be treated with herbicide; and (3) monitoring and surveillance of invasive species would 

increase, reducing the potential for new invasive species to become established on the trail 

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and spread into other locations such as into adjacent wetland habitats; and

• Potential conflict with other public use such as hunting, wildlife observation, photography 

will be minimized by using trail head signs and other media to inform the various users 

about current public uses; activities such as hunting are also located in areas closed to other 

public uses and occur during specified days thus reducing potential conflicts between uses.

Justification: Environmental education, and interpretation are priority general public uses as 

defined by Executive Order 12996 and the NWRS Administration Act of 1966, as amended by the 

NWRS Improvement Act of 1997 (Public Law 105-57), and when compatible, are to receive 

enhanced consideration over other general public uses. These uses are supportive of the Refuge’s 

purposes and the mission of the NWRS. One of this Refuge’s purposes is to provide opportunities 

for “nature study” and over the years since Refuge establishment has evolved to become one of the 

most robust environmental education and interpretative programs in the National Wildlife Refuge 

System. Environmental education and interpretation provide public access to the Refuge that 

increases understanding and often support of Refuge purposes and the wildlife resources found 

there, while focusing visitors to certain locations thus limiting impacts. 

The Refuge is one of the few areas in the urban South San Francisco Bay to be able to offer these 

uses. In the urban South Bay, the Refuge is the only location with former commercial salt ponds 

that are managed for wildlife. Therefore, there are no areas off the Refuge that can offer these 

wildlife oriented activities in this unique habitat. 

Potential for wildlife disturbance is minimized by restricting the disturbance to established trails 

with appropriate set-back distances (buffers) thus increasing predictability of public use patterns 

on the Refuge, allowing wildlife to habituate to non-threatening activities. Moreover, consolidating 

environmental education, interpretation and other compatible recreational activities to designated 

trails, located at the edge of the Refuge habitat boundary, reduces habitat fragmentation, thereby 

maintaining a core “sanctuary area” of the Refuge for more sensitive species.

The stipulations outlined above should minimize potential impacts relative to wildlife/human 

interactions. In particular, the adaptive management studies will determine the exact nature of the 

public use impacts on the Refuge’s wildlife and allow Refuge managers to adjust public use to 

further minimize wildlife impacts or discontinue those activities that are unacceptable. The 

proposed activities will not materially interfere or detract from the fulfillment of the NWRS 

Mission or the purposes of the Refuge.

Mandatory Reevaluation Date (provide month and year):

____X____ Mandatory 15-Year Reevaluation Date (for priority public uses)

__________ Mandatory 10-Year Reevaluation Date (for all uses other than priority 

public uses)

NEPA Compliance for Refuge Use Decision (check one below):

Conducted with Comprehensive Conservation Plan

______Categorical Exclusion without Environmental Action Statement

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______Categorical Exclusion and Environmental Action Statement

__X___Environmental Assessment and Finding of No Significant Impact

______Environmental Impact Statement and Record of Decision

References Cited:

Alcock, J. 1993. Animal behavior: an evolutionary approach. Fifth ed. Sinauer Assoc., Sunderland, 

MA. 625pp.

Dale, D. and T. Weaver. 1974. Trampling effects on vegetation of the trail corridors of north 

Rocky Mountain forests. J. Applied Ecology 11:767-772.

Federal Highway Administration. 2001. Designing sidewalks and trails for access, Part II, best 

practices design guide. U.S. Department of Transportation. Available on-line at: 

http://www.fhwa.dot.gov/environment/sidewalk2/ {last accessed on August 3, 2007}. 

Gabrielson, G.W. and E.N. Smith. 1995. Physiological responses of wildlife to disturbance. Pages 

95-107 in R.L. Knight and K.J. Gutzwiller (eds.), Wildlife and Recreationists: coexistence 

through management and research. Island Press, Washington, D.C. 372pp.

Goff, G.R., D.J. Decker and G. Pomerantz. 1988. A diagnostic tool for analyzing visitor impacts on 

wildlife refuges: A basis for a systematic approach to visitor management. Trans. Northeast 

Sect. Wildl. Soc. 45:82.

Hill, D., D. Hockin, D. Price, G. Tucker, R. Morris, and J. Treweek. 1997. Bird disturbance: 

improving the quality and utility of disturbance research. Journal of Applied Ecology 34:275-

288.

Hockin, D., M. Ounsted, M. Gorman, D. Hill, V. Keller, and M.A. Barker. 1992. Examination of the 

effects of disturbance on birds with reference to its importance in ecological assessments. 

Journal of Environmental Management 36:253-286.

Klein, M.L. 1993. Waterbird behavioral responses to human disturbances. Wildl. Soc. Bull. 21:31-

39.

Knight, R.L., and K.J. Gutzwiller, ed. 1995. Wildlife and Recreationists: coexistence through 

management and research. Island Press, Washington, D. C. 372 pp.

Klein, M.L., S.R. Humphrey, and H. F. Percival. 1995. Effects of ecotourism on distribution of 

waterbirds in a wildlife refuge. Conservation Biology 9:1454-1465.

Knight, R.L. and D.N. Cole. 1991. Effects of recreational activity on wildlife in wildlands in 

Transactions of the North American Wildlife and Natural Resources Conference. 56:238-247.

Oberbillig, D.R. 2000. Providing positive wildlife viewing experiences. Deborah Richie 

Communications, Missoula, MT.

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Purdy, K.G., G.R. Goft, D.J. Decker, G.A. Pomerantz, and N.A. Connelly. 1987. A guide to 

managing human activity on National Wildlife Refuges. Office of Information Transfer, U.S. 

Fish and Wildlife Service, Ft. Collins, CO. 57 pp.

Trulio L. and J. Sokale. 2007. Abstract: Waterbird response to trail use around the San Francisco 

Bay. Available at: www.southbayrestoration.org/Events-symposium.html {last accessed on 

August 3, 2007}. 

U.S. 16 U.S. C. 668dd-ee. 1966. National Wildlife Refuge System Administration Act.

U.S. Public Law 105-57. 1997. National Wildlife Refuge System Improvement Act. 

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Compatibility Determination for Waterfowl Hunting

Don Edwards San Francisco Bay NWR

Use: Waterfowl Hunting

Station Name: Don Edwards San Francisco Bay National Wildlife Refuge, Alameda, Santa Clara 

and San Mateo Counties, California

Date Established: June 30, 1972

 

Establishing and Acquisition Authorities: 

86 Stat. 399, dated June 30, 1972

An Act Authorizing the Transfer of Certain Real Property for Wildlife, or other purposes (16 

U.S.C. 667b)

Endangered Species Act of 1973 (16 U.S.C. 1534) 

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

Refuge Purpose(s): 

“... for the preservation and enhancement of highly significant wildlife habitat ... for the protection 

of migratory waterfowl and other wildlife, including species known to be threatened with 

extinction, and to provide an opportunity for wildlife-oriented recreation and nature study ...” (86 

Stat. 399, dated June 30, 1972).

“... particular value in carrying out the national migratory bird management program” 16 U.S.C. 

667b (An Act Authorizing the Transfer of Certain Real Property for Wildlife, or other purposes).

“... to conserve (A) fish or wildlife which are listed as endangered species or threatened species.... 

or (B) plants ...” 16 U.S.C. 1534 (Endangered Species Act of 1973).

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

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

Service, in performing its activities and services. Such acceptance may be subject to the terms of 

any restrictive or affirmative covenant, or condition of servitude ...” 16 U.S.C. 742f (b)(1) (Fish and 

Wildlife Act of 1956).

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” (National Wildlife 

Refuge System Administration Act of 1966, as amended [16 U.S.C. 668dd-668ee]).

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Description of Use: This compatibility determination is done as a review of the existing 

compatibility determination (1994) for waterfowl hunting, and in concert with the Don Edwards 

San Francisco Bay NWR Comprehensive Conservation Plan. This compatibility determination 

replaces the previous 1994 compatibility determination for waterfowl hunting.

Hunting is one of six public uses (the other uses are fishing, wildlife observation, photography, 

environmental education, and interpretation) given priority on refuges as defined by Executive 

Order 12996 and the National Wildlife Refuge System Administration Act of 1966 as amended by 

the National Wildlife Refuge System Improvement Act of 1997 (Public Law 105-57).

Waterfowl hunting is a common and accepted recreational activity on many units of the National 

Wildlife Refuge System. Opportunities to hunt waterfowl in South San Francisco Bay outside the 

Refuge are limited. The nearest areas open to hunting have been the State and Federal lands (San 

Pablo Bay National Wildlife Refuges) in the North San Francisco Bay (1.5 hour drive) with more 

extensive hunting opportunities in the Sacramento – San Joaquin Delta and the Central Valley (2.5 

to 5 hour drive). 

The Master Plan developed for the refuge in 1974 states: “Waterfowl hunting is a traditional sport 

on San Francisco Bay and a substantial amount of waterfowl hunting still occurs within the area to 

be acquired for the Refuge. Under existing policy and legal authority this activity may continue in 

the future as long as harvestable populations exist and hunting remains compatible with Refuge 

objectives”. Some of the waterfowl hunting that occurred in the South Bay was through leases 

with Cargill, Inc. on commercial salt production ponds. These leased ponds allowed a limited 

segment of the public to participate in this outdoor activity prior to refuge establishment. After 

establishment, regulated hunting was continued on certain areas of the refuge. Under the existing 

Refuge Hunt Plan first developed in 1982 and amended in 2004, approximately 10,280 acres (34 

percent) of this 30,000-acre Refuge is open to waterfowl hunting leaving 19,720 acres as sanctuary 

(66 percent). Habitats available for waterfowl hunting include former commercial salt evaporation 

ponds, tidal sloughs and tidal marshes.

 

This compatibility determination is done as a review of existing compatibility determinations for 

hunting and in concert with the Don Edwards San Francisco Bay NWR CCP. No new physical 

changes to the hunt program are prescribed under this compatibility determination. This 

compatibility determination combines and replaces all previous versions for hunting, described as 

follows.

The majority of the tidal areas on the Refuge are leased from the State of California. The existing 

lease from California State Lands Commission (SLC) encourages waterfowl hunting “unless it is 

determined after consultation with the State of California Department of Fish and Game that the 

area be closed because of the public safety, for waterfowl resource protection, or for administrative 

purposes.” This lease language is based upon the historic “Public Trust” doctrine, which requires 

that State-owned tidelands remain open to “commerce, navigation and fisheries.” Courts have 

ruled that the Public Trust also includes the right to hunt. The existing lease requirement with 

SLC (since 1980) is consistent with the National Wildlife Refuge System Improvement Act of 1997, 

which considers hunting a “priority public use”, when found compatible with the mission of the 

National Wildlife Refuge System and the purposes for which the Refuge was established.

The hunt season is set by the California Department of Fish & Game and generally occurs from 

mid-October to late January. The hunting program is regulated by both the California 

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Department of Fish and Game and the Refuge. Information on hunting regulations can be found 

at: http://www.dfg.ca.gov/ and http://www.fws.gov/desfbay/Hunt/Hunt_Information.htm. All 

Refuge hunting areas are boat-access only, except for Ravenswood and Ponds A5-A8. 

Figure 1 identifies areas within the Refuge that are open to hunting.

The Refuge has three hunter check-in stations. They are located at Ponds A3W, A2E, and A5. 

Using data derived from these stations, it is estimated that there are over 2,000 hunter visits 

annually on the southernmost hunting areas within the Refuge (Table 1). 

Table 7. Hunt Information for Alviso Area

Year # Hunters # Ducks # Ducks per 

Hunter

# Geese # Geese per 

Hunter

Total Birds Total Birds 

per Hunter

2005 1028 2261 2.2 41 .04 2302 2.2

2006 1665 3304 2.0 35 .02 3339 2.0

2007 2464 7231 2.9 88 .04 7319 3.0

2008 1960 2180 1.1 46 .02 2226 1.1

2009 1126 2549 2.3 40 .04 2589 2.3

2010 1789 2557 1.4 24 .01 2581 1.44

In addition to the state determined rules and regulations, the Refuge specific rules are: 

 

1. Hunting is allowed three days a week (Wednesdays, Saturdays and Sundays) on the 

following ponds: AB1, A2E, AB2, A3N, A3W, A5, A7 and A8. In addition to State Hunting 

Licenses, hunters of these ponds need a Refuge Special Use Permit. Ponds A1, A2W, A6, 

A9,A10,A11, A12, A13, A14, A15, A16,A20, A21, A22, A23, R3, R4, R5, RSF-2 and RS5 are 

closed to waterfowl hunting to serve as wildlife sanctuaries, protect endangered species, 

and reduce conflict with adjacent landowners. All blinds are located at least 150 yards from 

any public trail or dwelling.

2. Access to Ponds AB1 and A2E is from the Crittenden Lane Trailhead in Mountain View. 

Access to Pond A3W is from the Carl Road Trailhead in Sunnyvale. Access to Ponds A3N 

and AB2 is by boat from the other ponds. Hunting is only allowed from existing hunting 

blinds for these 5 ponds. 

3. Access to Ponds A5, A7, and A8 is by foot/ bicycle from the Gold Street Gate in Alviso. In 

these three ponds hunting is restricted to existing hunting blinds, hunting from boat, and 

walking on pond levees. 

4. During the two weekends before opening of the hunt season, hunters may bring a boat into 

Ponds AB1, A2E, AB2, A3N, A3W, A5, A7 and A8 to be used to access the hunting blinds 

and moor it at a designated site if they have a valid Refuge Special Use Permit. Hunters 

are allowed to leave their boat in the ponds during the season and remove them within two 

weeks following close of the hunt season. Permitted boats are as follows: non- motorized, 

electric motors, and two or four-stroke gasoline motors. Once the season opens, hunters 

are only allowed in hunt areas on hunt days (no scouting trips will be allowed).

5. Hunters may maintain an existing blind if they have a valid Refuge Special Use Permit, but 

the blind will be open for general use on a first-come, first-served basis. We prohibit pit 

blinds or digging into the levees. 

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6. Hunters may enter closed areas of the refuge to retrieve downed birds, provided they leave 

all weapons in a legal hunting area (unless a crippled bird is downed in closed area, a 

weapon is allowed to dispatch wounded birds). The Refuge encourages the use of retriever 

dogs. They must keep the dog(s) under control at all times. These dogs must be in a 

vehicle or on a leash until they are on the ponds as a part of the hunt or on the levees 

(Ponds A5, A7, A8, and Ravenswood Ponds only) as a part of the hunt. 

7. Dog handlers must have a hunt license and must be out only during the hunting season. No 

dog training activities are allowed.

8. Hunting in the Ravenswood Unit and Mowry Unit ponds is allowed seven days per week 

during the hunt season with a Refuge Special Use Permit. The Ravenswood ponds are 

accessible by foot or bicycle, and shooting is allowed from the levee only. The Mowry Unit 

is assessable only by boat, and hunting is allowed from a boat inside the ponds. There is no 

self-check in box for these two areas.

9. Other hunting areas do not require a Special Use Permit from the Refuge. These areas 

include Bair Island, Greco Island and the open bay. Access to these areas is only by boat, 

and hunting is allowed only from a boat; no land access is permitted unless to retrieve 

downed birds. Hunting is not allowed from outside a boat when on Refuge lands. Bair 

Island, Greco Island and the open Bay are open to hunting seven days a week.

10. At the end of the regular hunt season, the State usually opens the next weekend following 

the close of the season for junior hunters. All junior hunters must be under the age of 16 at 

the beginning of the license year, and accompanied by an adult (adults are not permitted to 

hunt during junior hunt days). The Refuge participates in the Junior Hunt Program if 

offered by the State.

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Figure 1. Refuge Hunt Areas

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Availability of Resources: Existing staff are adequate to offer the hunt program to the public. 

Approximately 1,250 staff days is required to monitor and conduct the Program. This includes 

opening all the ponds two weekends before the opening of hunt season and two weekends after the 

closing of the season to allow hunters to place and retrieve small boats in the ponds and maintain 

blinds under Refuge Special Use Permits. Staffing activities also includes law enforcement, sign 

posting, graveling entrance roads, responding to public inquiries and issuance of Special Use 

Permits. There is sufficient staffing to enforce regulations by Refuge law enforcement officers. 

When possible, the California Waterfowl Association and local hunters partner with Refuge staff to 

hold organized work parties to assist with blind and boat dock maintenance at the ponds before 

each hunting season. However, additional funding is needed for maintenance of the hunt program 

infrastructure and outreach. An annual waterfowl hunt fee program would be developed in order 

to fund these maintenance needs (e.g., provide improvements to hunt blinds, hunt access, and 

outreach and education materials).

Anticipated Impacts: 

Direct effects of hunting include mortality, wounding, and disturbance (De Long 2002). Hunting 

can alter behavior (e.g., foraging time), population structure, and distribution patterns of wildlife 

(Owens 1977, Raveling 1979, White-Robinson 1982, Thomas 1983, Bartelt 1987, Madsen 1985, and 

Cole and Knight 1990). There also appears to be an inverse relationship between the numbers of 

birds using an area and hunting intensity (DeLong 2002). In Connecticut, lesser scaup were 

observed to forage less in areas that were heavily hunted (Cronan 1957). Boating activities (e.g., 

for fishing, hunting) can also displace waterfowl from feeding grounds and increase energetic costs 

associated with flight (Korschgen and Dahlgren 1992). In California, the numbers of northern 

pintails on Sacramento National Wildlife Refuge non-hunt areas increased after the first week of 

hunting and remained high until the season was over in early January (Heitmeyer and Raveling 

1988). Following the close of hunting season, ducks generally increased their use of the hunt area; 

however, use was lower than before the hunting season began. Human disturbance associated with 

hunting includes loud noises and rapid movements, such as those produced by shotguns and boats 

powered by outboard motors. This disturbance, especially when repeated over a period of time, 

compels waterfowl to change food habits, feed only at night, lose weight, or desert feeding areas 

(Madsen 1995, Wolder 1993). 

Potential impacts to wildlife may also occur through the use of boating to facilitate hunting. Both 

motorized and non-motorized boating can alter wildlife behavior. Though motorized boats 

generally have a greater effect on wildlife, even non-motorized boat use can alter distribution, 

reduce use of particular habitats by waterfowl and other birds, alter feeding behavior and 

nutritional status, and cause premature departure from areas (Knight and Cole 1995). However, 

compared to motorboats, canoes and kayaks appear to have less disturbance effects on most 

wildlife species (DeLong 2002). Disturbance to birds in general is reduced when boats travel at or 

below the five mile per hour speed limit. 

Individual animals may be disturbed by human contact to varying degrees. Studies have shown 

that birds can be impacted by human activities when they are disturbed and flushed from feeding, 

resting, or nesting areas. Flushing, especially repetitive flushing, can strongly impact habitat use 

patterns of many bird species. Flushing from an area can cause birds to expend more energy, be 

deterred from using desirable habitat, affect resting or feeding patterns, and increase exposure to 

predation or cause birds to abandon sites with repeated disturbance (Smith and Hunt 1995). 

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Migratory birds are observed to be more sensitive than resident species to disturbance (Klein 

1989).

Impacts can be reduced by the presence of adjacent sanctuary areas where hunting does not occur 

and where birds can feed and rest relatively undisturbed. Sanctuaries or non-hunt areas have been 

identified as the most common solution to disturbance problems caused from hunting (Havera et al. 

1992). Prolonged and extensive disturbances may cause large numbers of waterfowl to leave 

disturbed areas and migrate elsewhere (Madsen 1995, Paulus 1984). In Denmark, hunting 

disturbance effects were experimentally tested by establishing two sanctuaries (Madsen 1995). 

Over a 5-year period, these sanctuaries became two of the most important staging areas for coastal 

waterfowl. Numbers of dabbling ducks and geese increased 4 to 20 fold within the sanctuary 

(Madsen 1995). Thus, sanctuary and non-hunt areas are very important to minimize disturbance to 

waterfowl populations to ensure their continued use of the Refuge.

Intermittent hunting can be a means of minimizing disturbance, especially if rest periods in 

between hunting events are weeks rather than days (Fox and Madsen 1997). It is common for 

refuges to manage hunt programs with non-hunt days. At Sacramento National Wildlife Refuge, 3-

16 percent of pintails were located on hunted units during non-hunt days, but were almost entirely 

absent in those same units on hunt days (Wolder 1993). In addition, northern pintails, American 

wigeons, and northern shovelers decreased time spent feeding on days when hunting occurred on 

public shooting areas, as compared to non-hunt days (Heitmeyer and Raveling 1988). The 

intermittent hunting program of three hunt days per week at Sacramento Refuge results in lower 

pintail densities on hunt areas during non-hunt days than non-hunt areas (Wolder 1993). However, 

intermittent hunting may not always greatly reduce hunting impacts. 

Hunting is a highly regulated activity, and generally takes place at specific times and seasons (fall 

and winter) when the game animals are less vulnerable, reducing the magnitude of disturbance to 

refuge wildlife. Managed and regulated hunting will not reduce species populations to levels where 

other wildlife-dependent uses will be affected.

The use of retrieving dogs is encouraged in all areas open to waterfowl hunting. These dogs will be 

required to be under control at all times. Law enforcement officers will enforce regulations 

requiring owners to maintain control over their dogs while on the Refuge. Although the use of 

dogs is not a form of wildlife-dependent recreation, they do in this case support a wildlifedependent use. Implementing the prescribed restrictions outlined in the Stipulations section 

should alleviate any substantial impacts.

By its very nature, hunting has very few positive effects on the target species while the activity is 

occurring. However, in our opinion, hunting has given many people a deeper appreciation of 

wildlife and a better understanding of the importance of conserving their habitat, which has 

ultimately contributed to the Refuge System mission. Furthermore, despite the potential impacts 

of hunting, a goal of the Refuge is to provide visitors of all ages an opportunity to enjoy wildlifedependent recreation. Of key concern is to offer a safe and quality program and to ensure adverse 

impacts remain at an acceptable level.

Recreational hunting will remove individual animals, but will not negatively affect waterfowl 

populations. To assure that waterfowl populations are sustainable, the California Fish and Game 

Commission, in consultation with the CDFG, will continue to annually review the population 

censuses to establish season lengths and harvest levels within the guidelines developed by the 

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Service based on annual overall waterfowl population estimates. The areas closed to various 

hunting activities were designed to provide adequate sanctuaries for wildlife. 

Hunters also may trespass into sensitive habitats. Hunting beyond the open bay waters or 

navigable sloughs in non-designated sites, into the interior of the marsh or other restricted areas 

would result in disturbance to endangered species such as the salt marsh harvest mouse 

(Reithrodontomys raviventris raviventris) and California clapper rail (Rallus longirostris), as well 

as shorebirds, wading birds, and songbirds. The Service will protect these habitats and resources 

with signage and hunting brochures to increase hunter awareness. Restrictions will be enforced 

through law enforcement field checks. In addition, unauthorized human access in fragile tidal 

marsh habitat could cause trampling creating a lower quality marsh and creating trails for 

mammalian predators. Hunting in tidal areas is restricted to boats only, retrieval dogs may be 

used in boat only areas and may cause disturbance to wildlife. Hunters must have command of 

dogs at all time.

The Service believes that there will be minimal conflicts between hunters and the other wildlifedependent recreational uses. The hunted tidal areas have minimal conflict because of estimated 

low hunt participation numbers and limited interaction between the users. While the open bay is 

open to hunting, these areas are not known to be frequented by visitors for wildlife observation and 

photography. The majority of the Refuge ponds open to hunting are not open to other recreational 

users therefore, there is no conflict among user groups. Ponds AB1, AB2, A2E and A3W are open 

to hunting and are visible from the Moffett Bay Trail, one of the more popular public use trails on 

the Refuge. Signs are posted by Refuge staff to advise trail users about hunting activity in the 

vicinity. Refuge staff has received few complaints about the hunting program along this trail, thus 

indicating low user conflicts.

Therefore, some wildlife disturbance will occur during the hunting seasons. Proper zoning, timing 

and other regulation will continue to be utilized to minimize negative impacts to wildlife 

populations using the Refuge. Harvesting these species, or any other hunted species, would not 

result in a substantial decrease in biological diversity on the Refuge.

Public Review and Comment: 

Public review and comments were solicited in conjunction with distribution of the Draft CCP/EA 

for Don Edwards San Francisco Bay NWR, released in May 2012. Comments were made with 

regard to waterfowl hunting, but not directly to this compatibility determination. Comments and 

response to comments on waterfowl hunting are located in Appendix O of the CCP.

Determination: 

_______ Use is Not Compatible

___X___ Use is Compatible with Stipulations

The following stipulations are required to ensure compatibility: 

• The Refuge must maintain an effective law enforcement program to protect Refuge 

resources and the visiting public. Environmental education and outreach will remain a key 

component and priority for the Refuge. Hunting outreach brochures will be made available 

to the public at the Refuge offices, through Refuge law enforcement officers and other staff 

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and via the Refuge web site.

• The use of retrieving dogs will be permitted and encouraged in all areas open to hunting. 

Dogs must be under control at all times. Dogs will be required to be kept on leash, except 

when engaged in authorized hunting activities and under the direct voice control of a 

licensed hunter.

• In addition to the State-determined rules and regulations, refer to the section prior, 

Description of Use, for Refuge specific rules for hunting.

• Boats used for hunting will be limited to navigable sloughs, open waters, and specified 

managed ponds.

• The following areas will be closed to hunting by boat: Mallard Slough, March 1 – August 31 

and Mowry Slough and Steinberger Slough, March 15 – June 15.

• Boats used for hunting must adhere to the California Boating Law. This information will 

be available to the public at appropriate access points on the Refuge, the headquarters 

visitor center, Alviso Environmental Educational Center and via the Refuge’s web site.

Justification: Hunting is one of six priority public uses (the other uses are fishing, wildlife 

observation, photography, environmental education, and interpretation) encouraged in the 

National Wildlife Refuge System Improvement Act of 1997 (Public Law 105-57). Hunting would 

allow the visiting public to enjoy, experience, and learn about the unique and rare habitats of 

southern San Francisco Bay region. 

Waterfowl hunting is determined to be compatible, in view of the potential impacts that hunting 

and supporting activities (i.e. motorized and non-motorized boating, driving vehicles, bicycling, and 

walking on pond levees, and use of dogs) can have on our ability to achieve Refuge purposes and 

the mission of the National Wildlife Refuge System, because: 1) sufficient restrictions have been 

placed on hunting, driving, bicycling, walking, boating and use of dogs to ensure that (a) an 

adequate amount of sanctuary would be available to accommodate the needs of waterfowl and other

wetland birds using the Refuge (i.e., no more than 40 percent open to hunting [605 FW 2]), and (b) 

hunting would not detract from other existing wildlife-dependent uses such as wildlife observation, 

photography, environmental education and interpretation 2) the hunt would be managed under the 

State waterfowl hunting regulations that are specifically designed to maintain healthy waterfowl 

populations along the Pacific Flyway of which the Refuge is a part, and 3) effective monitoring is 

conducted on hunter use, regulation compliance and overall impacts to waterfowl and other wildlife 

utilizing this information to make necessary adjusts to maintain the compatibility of the hunt 

program.

Although boating, driving to the ponds, use of dogs, bicycling, and walking the levees are not forms 

of wildlife-dependent recreation; they do in this case support a wildlife dependent use. 

Implementing the prescribed restrictions on boating, dogs, bicycling and walking outlined in the 

Stipulations section should alleviate any substantial impacts. Allowing use of private vehicles to 

access the ponds will increase their accessibility for those hunters will physical limitations.

An adequate amount of waterfowl sanctuary would be available to waterfowl and other water 

dependent wildlife. The total acreage of the Refuge which would be open to hunting is 10,280 acres 

(34%). On this 30,000-acre Refuge, 19,720 acres would be sanctuary (66%). Thus, it is anticipated 

that waterfowl and other highly mobile wildlife species would find sufficient food resources and 

resting places such that distribution from hunting would not be substantially impacted. 

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The Service’s policy on Biological Integrity, Diversity, and Environmental Health requires that 

Refuge actions at least maintain existing levels of biological integrity, diversity and environmental 

health. This Hunt Program allows for waterfowl hunting on selected Refuge ponds under State 

harvest regulations which are designed to maintain the diversity and integrity of the flyway 

waterfowl population. Therefore, it would at least maintain existing levels as required in the policy.

Mandatory Reevaluation Date (provide month and year):

____X____ Mandatory 15-Year Reevaluation Date (for priority public uses)

________ Mandatory 10-Year Reevaluation Date (for all uses other than priority 

public uses)

NEPA Compliance for Refuge Use Decision (check one below):

Conducted with Comprehensive Conservation Plan

_______Categorical Exclusion without Environmental Action Statement

_______Categorical Exclusion and Environmental Action Statement

___X___Environmental Assessment and Finding of No Significant Impact

_______Environmental Impact Statement and Record of Decision

References Cited: 

Bartelt, G. A. 1987. Effects of disturbance and hunting on the behavior of Canada goose family 

groups in east central Wisconsin. Journal of Wildlife Management 51:517-522.

Cole, D. N., and R. L. Knight. 1990. Impacts of recreation on biodiversity in wilderness. Utah 

State University.

Cronan, J. M. 1957. Food and feeding habits of the scaups in Connecticut waters. Auk 74(4):459-

468.

DeLong, A. K. 2002. Managing visitor use and disturbance of waterbirds - literature review of 

impacts and mitigation measures - prepared for Stillwater National Wildlife Refuge. 

Appendix L. In Stillwater National Wildlife Refuge Complex final environmental impact 

statement for the comprehensive conservation plan and boundary revision (Vol. II).

Fox, A. D., and J. Madsen. 1997. Behavioral and distributional effects of hunting disturbance on 

waterbirds in Europe: implications for refuge design. Journal of Applied Ecology 34:1-13.

Havera, S. P., L. R. Boens, M. M. Georgi, and R. T. Shealy. 1992. Human disturbance of waterfowl 

on Keokuk Pool, Mississippi River. Wildlife Society Bulletin 20:290-298.

Heitmeyer, M. E., and D. G. Raveling. 1988. Winter resource use by three species of dabbling 

ducks in California. Final report to Delta Waterfowl and Wetlands Research Center.

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Klein, M. 1989. Effects of high levels of human visitation on foraging waterbirds at J. N. "Ding" 

Darling National Wildlife Refuge, Sanibel Florida. Master’s thesis. Gainesville, Florida: 

University of Florida.

Knight, R.L. and D.N. Cole. 1995. Wildlife responses to recreationists. Pages 71-79 in R.L. 

Knight and K.J. Gutzwiller, eds. Wildlife and Recreationists: coexistence through 

management and research. Island Press, Washington, D.C. 372 pp.

Korshgen, C.E. and R.B. Dahlgren. Human Disturbances of Waterfowl: Causes, Effects, and 

Management. In Waterfowl Management Handbook, Fish and Wildlife Leaflet 13.2.15. 

Washington, D.C.

Madsen, J. 1985. Impact of disturbance on field utilization of pink-footed geese in West Jutland, 

Denmark. Biological Conservation 33:53-63.

Madsen, J. 1995. Impacts of disturbance on migratory waterfowl. Ibis 137:S67-S74.

Owens, N. W. 1977. Responses of wintering brant geese to human disturbance. Wildfowl 28:5-14.

Paulus, S. L. 1984. Activity budgets of nonbreeding gadwalls in Louisiana. Journal of Wildlife 

Management 48:371-380.

Raveling, D. G. 1979. The annual cycle of body composition of Canada geese with special reference 

to control of reproduction. Auk 96:234-252.

Smith, L. and J. D. Hunt. 1995. Nature tourism: impacts and management. Pp. 203-219 in Knight, 

R. L.; Gutzwiller, K. J. (Wildlife and recreationists: coexistence through management and 

research, eds.). Island Press, Washington, D. C.

Thomas, V.G. 1983. Spring migration: the prelude to goose reproduction and a review of its 

implication. In Fourth Western Hemisphere Waterfowl and Waterbird Symposium, edited 

by H. Boyd. Ottawa, Canada: Canadian Wildlife Service.

U.S. Fish and Wildlife Refuge. 2001. Biological Integrity, Diversity, and Environmental Health 

Policy 601 FW 3

U.S. Fish and Wildlife Refuge. 1982. San Francisco Bay NWR Refuge Hunt Plan & 

Environmental Assessment.

White-Robinson, R. 1982. Inland and salt marsh feeding of wintering brent geese in Essex. 

Wildfowl 33:113-118.

Wolder, M. 1993. Disturbance of wintering northern pintails at Sacramento National Wildlife 

Refuge, California. Master's thesis, Humboldt State University, Arcata, California.

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Compatibility Determination for Recreational Boating on Don Edwards San Francisco Bay 

National Wildlife Refuge

Uses: Recreational Boating

Refuge Name: Don Edwards San Francisco Bay National Wildlife Refuge, Alameda, Santa Clara 

and San Mateo Counties, California

Establishing and Acquisition Authorities:

86 Stat. 399, dated June 30, 1972

An Act Authorizing the Transfer of Certain Real Property for Wildlife, or other purposes (16 

U.S.C. 667b)

Endangered Species Act of 1973 (16 U.S.C. 1534) 

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

Refuge Purpose(s):

“... for the preservation and enhancement of highly significant wildlife habitat ... for the protection 

of migratory waterfowl and other wildlife, including species known to be threatened with 

extinction, and to provide an opportunity for wildlife-oriented recreation and nature study ...” (86 

Stat. 399, dated June 30, 1972).

“... particular value in carrying out the national migratory bird management program” 16 U.S.C. 

667b (An Act Authorizing the Transfer of Certain Real Property for Wildlife, or other purposes).

“... to conserve (A) fish or wildlife which are listed as endangered species or threatened species.... 

or (B) plants ...” 16 U.S.C. 1534 (Endangered Species Act of 1973).

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

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

Service, in performing its activities and services. Such acceptance may be subject to the terms of 

any restrictive or affirmative covenant, or condition of servitude ...” 16 U.S.C. 742f (b)(1) (Fish and 

Wildlife Act of 1956).

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.” (National 

Wildlife Refuge System Administration Act of 1966, as amended [16 U.S.C. 668dd - 668ee.])

Description of Use(s): This compatibility determination is done in concert with the Don Edwards 

NWR Comprehensive Conservation Plan (CCP). The National Wildlife Refuge System 

Improvement Act of 1997 identifies fishing, hunting, wildlife observation, photography, 

environmental education, and interpretation as the six priority public uses on refuges. The use 

generally includes motorized and non-motorized boating to facilitate wildlife research, hunting, 

environmental education, wildlife observation, wildlife photography and fishing. 

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The Refuge’s navigable sloughs and open waters will be open to recreational boating. The majority 

of these waters is leased from the State of California Lands Commission (SLC) and managed as 

part of the Refuge; they are extremely important waters due to existing fish and wildlife 

populations. While there are currently no boat launches available on the Refuge, boat access to the 

bay is available in Redwood City, Newark, and Alviso (See Figure 1). A canoe and kayak site 

(potentially near Dumbarton Bridge/fishing pier) will be explored and implemented if feasible on 

the Refuge, as stated in the CCP.

Boats will be permitted to enter the Refuge’s navigable sloughs and open waters to facilitate the 

public’s participation in wildlife observation, wildlife photography, environmental education, 

waterfowl hunting, and fishing. In the Refuge’s managed ponds, boats are permitted during 

waterfowl season to facilitate hunting. No jet skis or other personal motorized vehicles will be 

permitted within the managed ponds. 

Due to presence of sensitive wildlife species, no boat access will be permitted within Mowry Slough, 

from March 15 – June 15. Additional areas may be closed to boat access as needed. Eventual tidal 

marsh formation is expected to occur as managed ponds are restored to tidal action through 

restoration efforts such as the South Bay Salt Pond Restoration Project. As these sites become 

occupied by listed species, additional restrictions to public access may be necessary. 

All boating opportunities will be implemented in a manner to ensure protection for listed species 

and migratory birds by providing law enforcement patrols, education and outreach conducted on 

site as well as tours and other group programs to create an environmental awareness of 

stewardship for wildlife and habitat of the Refuge. Public use activities will be allowed during 

daylight hours only. 

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Figure 2. Boat Launches Near Don Edwards San Francisco Bay NWR

C-81
Availability of Resources:

Additional funding and staffing is needed to encourage compatible boating activities. Staffing to 

develop and maintain outreach material (e.g., signage, brochures, websites, etc.) to assist in 

protection of wildlife and their habitats would be needed along with increased law enforcement 

patrols in sensitive areas of the Refuges such as Mowry Slough. Funding will be needed to 

construct the canoe and kayak site, as well as the related signage and outreach materials.

Item One-Time Cost Annual Costs

Refuge Law Enforcement (0.1 FTE) N/A $6,500

Outdoor Recreation Planner (0.1 

FTE)

N/A $7,600

Signage, outreach materials at 

launch sites to reduce disturbance

$30,000 $3,000

Canoe and kayak site on the 

Refuge (e.g., near Dumbarton 

Bridge/fishing pier), 

interpretive/informational signage

$20,000 $1,000

TOTAL $50,000 $18,100

 

Anticipated Impacts:

Large numbers of waterfowl, shorebirds, fish and other wildlife species use the Refuge for feeding, 

resting and in some cases, breeding. Sensitive fish species occur within the Refuge including the 

green sturgeon (Acipenser medirostris), steelhead salmon (Oncorhynchus mykiss), and the 

Chinook salmon (Oncorhynchus tshawytscha). The presence of boats should not create any longterm effects on fish and wildlife species. 

Open water and tidal areas of the Refuge provide habitat for other sensitive species including the 

California clapper rail, California black rail, western snowy plover, and salt marsh harvest mouse. 

Potential impacts to these wildlife may occur through the use of boating. Individual animals may 

be disturbed by human contact to varying degrees. Studies have shown that birds can be impacted 

from human activities when they are disturbed and flushed from feeding, resting, or nesting areas. 

Flushing, especially repetitive flushing, can strongly impact habitat use patterns of many bird 

species. Flushing from an area can cause birds to expend more energy, be deterred from using 

desirable habitat, affect resting or feeding patterns, and increase exposure to predation or cause 

birds to abandon sites with repeated disturbance (Smith and Hunt 1995). Migratory birds are 

observed to be more sensitive than resident species to disturbance (Klein 1989).

Harbor seals may be impacted by boating. A 2008 study of the behavioral response of harbor seals 

to boaters at Bair Island found that seal vigilance increased as boats passed the haul-out, and as 

boats came closer to the seals. Within ten minutes of the disappearance of the boats, the seals 

relaxed. During 70% of the boating events, seals did not flush, remaining at the haul-out. When 

flushing did occur, the seals almost always recovered within the large haul-out area. However, 

total seal numbers observed during days with multiple boats were lower than observed on days 

without boating activity (Fox 2008).

C-82
Though motorized boats generally have a greater effect on wildlife, even non-motorized boat use 

can alter distribution, reduce use of particular habitats by waterfowl and other birds, alter feeding 

behavior and nutritional status, and cause premature departure from areas (Knight and Cole 1995). 

However, compared to motorboats, canoes and kayaks appear to have less disturbance effects on 

most wildlife species and disturbance to birds in general is reduced when boats travel at or below 

the 5 mile per hour speed limit (DeLong 2002). 

The proposed use would not significantly impact the ability of the Refuge to protect wildlife, 

diverse tidal marsh, seasonal wetland habitats and adjacent transitional uplands critical to the

needs of migratory birds and listed species. Many acres of the Refuge are currently open to public 

access including boating. While some disturbance to waterbird populations occurs, significant 

habitat remains available that is inaccessible or closed to public access. To reduce disturbance, 

speed restrictions on motorized boats within some areas will be implemented. In addition, 

outreach to the public will be increased to promote awareness of the importance of habitats within 

and around the Refuge. Environmental Education is critical for making visitors aware that their 

actions can have negative impacts on wildlife, and will increase the likelihood that visitors will abide 

by restrictions on their actions. For example, Klein (1993) demonstrated that visitors who spoke 

with refuge staff or volunteers were less likely to disturb birds. 

Public Review and Comment:

Public review and comments were solicited in conjunction with distribution of the Draft CCP/EA 

for Don Edwards San Francisco Bay NWR, released in May 2012. One commenter requested that 

further analysis on boating impacts to harbor seals in the CD. Information on boating impacts was 

added to the “Anticipated Impacts” section.

Determination (Check One Below):

_______ Use is Not Compatible

___X___ Use is Compatible with Stipulations

 

Stipulations Necessary to Ensure Compatibility:

• Recreational boating will be limited to navigable sloughs and open waters except as allowed 

to facilitate waterfowl hunting in managed ponds.

• The following areas will be closed to boating: Mallard Slough, March 1 – August 31 and 

Mowry Slough and Steinberger Slough, March 15 – June 15.

• Boats must adhere to the California Boating Law. This information will be available to the 

public at appropriate access points on the Refuge, the headquarters visitor center, Alviso 

Environmental Educational Center and via the Refuge’s web site.

• Fishing and boating brochures and signage will be developed to inform users of regulations 

and etiquette to reduce wildlife disturbance. A “Boating on the Refuge” brochure will be 

updated and made available to the public at the Refuge Office in Fremont, Alviso 

Environmental Education Center, and on the Refuge website. Information provided in this 

brochure will include no-wake speed limits, seasonal or specific area closures, and a map of 

trails in the adjacent sloughs.

• Increased law enforcement will be needed to ensure compliance with all state and federal 

regulations.

• Monitoring of habitats and species in all areas where boating occurs will take place during 

biological surveys. If habitat or wildlife disturbance is determined to be detrimental, 

C-83
modifications to this use will be implemented to keep boat use on the Refuge compatible.

Justification:

Although boating is not considered wildlife-dependent recreation, many activities identified in the 

Refuge Improvement Act of 1997, particularly hunting, fishing, wildlife observation and 

photography) are facilitated by this use. Recreational boating would allow the visiting public to 

enjoy, experience, and learn about native fish, wildlife and their habitats of south San Francisco 

Bay. 

Mandatory Re-evaluation Dates (Provide Month and Year)

_______ Mandatory 15-year Reevaluation Date (for priority public uses)

___X___ Mandatory 10-year Reevaluation Date (for all uses other than priority public uses)

NEPA Compliance (Check One Below)

_____ Categorical Exclusion and Environmental Action Statement

__X__ Environmental Assessment and Finding of No Significant Impact

_____ Environmental Impact Statement and Record of Decision

References Cited:

DeLong, A. 2002. Managing Visitor Use & Disturbance of Waterbirds. A Literature Review of 

Impacts and Mitigation Measures.

Fox, K. S. 2008. Harbor seal behavioral reponse to boaters at Bair Island refuge. Master's 

Theses. Paper 3591. http://scholarworks.sjsu.edu/etd_theses/3591.

Klein, M. 1989. Effects of high levels of human visitation on foraging waterbirds at J.N. “Ding” 

Darling National Wildlife Refuge, Sanibel Florida. Masters thesis. Gainsville, Florida: 

University of Florida.

Klein, M. 1993. Waterbird behavioral responses to human disturbances. Wildl. Soc. Bull. 

21:31-39.

Knight, R.L. and D.N. Cole. 1995. Wildlife responses to recreationists. Pages 71-79 in R.L. Knight 

and K.J. Gutzwiller, ed. Wildlife and Recreationists: coexistence through management and 

research. Island Press, Washington, D.C. 372 pp.

Smith, L. and J.D. Hunt. 1995. Nature tourism: impacts and management. Pp. 203-219 in 

Knight, R.L; Gutzwiller, K.J. (Wildlife and recreationists: coexistence through 

management and research, eds.). Island Press, Washington, D.C.

C-84

C-86
Compatibility Determination for Recreational Fishing on 

Don Edwards San Francisco Bay NWR

Use: Recreational Fishing

Refuge Name: Don Edwards San Francisco Bay National Wildlife Refuge, Alameda, Santa Clara 

and San Mateo Counties, California.

 

Establishing and Acquisition Authorities: 

86 Stat. 399, dated June 30, 1972

An Act Authorizing the Transfer of Certain Real Property for Wildlife, or other purposes (16 

U.S.C. 667b)

Endangered Species Act of 1973 (16 U.S.C. 1534) 

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

 

Refuge Purpose(s): 

“... for the preservation and enhancement of highly significant wildlife habitat ... for the protection 

of migratory waterfowl and other wildlife, including species known to be threatened with 

extinction, and to provide an opportunity for wildlife-oriented recreation and nature study ...” (86 

Stat. 399, dated June 30, 1972).

“... particular value in carrying out the national migratory bird management program” 16 U.S.C. 

667b (An Act Authorizing the Transfer of Certain Real Property for Wildlife, or other purposes).

“... to conserve (A) fish or wildlife which are listed as endangered species or threatened species.... 

or (B) plants ...” 16 U.S.C. 1534 (Endangered Species Act of 1973).

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

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

Service, in performing its activities and services. Such acceptance may be subject to the terms of 

any restrictive or affirmative covenant, or condition of servitude ...” 16 U.S.C. 742f (b)(1) (Fish and 

Wildlife Act of 1956).

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” (National Wildlife 

Refuge System Administration Act of 1966, as amended [16 U.S.C. 668dd-668ee]).

Description of Use: This compatibility determination is undertaken as a review of the existing 

compatibility determination for recreational fishing (1994) and in concert with the Don Edwards 

San Francisco Bay NWR Comprehensive Conservation Plan (CCP). This compatibility 

determination replaces the previous 1994 compatibility determination for recreational fishing. 

Fishing is one of six public uses (the other uses are hunting, wildlife observation, photography, 

environmental education, and interpretation) given priority on refuges as defined by Executive 

C-87
Order 12996 and the National Wildlife Refuge System Administration Act of 1966 as amended by 

the National Wildlife Refuge System Improvement Act of 1997 (Public Law 105-57). 

Shoreline fishing opportunities are limited on the Refuge due to the shallow geography of the Bay. 

This geography makes it difficult, and in most places impossible, to access waters deep enough to 

catch fish. Fishing is currently allowed on the Refuge from the pier at the end of Marshlands Road 

in Fremont, at the shoreline of the Faber-Laumeister sub-unit, at the shoreline of Coyote Creek 

near Coyote Creek Lagoon, and from the platform at Mallard Slough Trail. Fishing is also allowed 

by boat on the portions of the South Bay and sloughs within the Refuge. All fishing is regulated by 

the California Department of Fish and Game and information on sport fishing regulations can be

found at: http://www.dfg.ca.gov/. 

Portions of the South Bay’s navigable sloughs and open waters are leased from the State of 

California Lands Commission (SLC) and managed as part of the Refuge. Under the existing lease 

with SLC, the Service is encouraged to allow “... waterfowl hunting and fishing ... unless it is 

determined after consultation with the State of California Department of Fish and Game that the 

area be closed because of the public safety, for waterfowl resource protection, or for administrative 

purposes.” The original lease language is based upon the historic “Public Trust” doctrine, which 

requires that State-owned tidelands remain open to “commerce, navigation and fisheries.”

The Refuge’s sloughs and open waters are extremely important angling waters due to significant 

fish populations and the proximity to safe road access and boat launches in Newark near the 

Refuge Headquarters, in Alviso and Redwood City. These facilities enable public access to the 

Refuge for the neighboring communities of Alameda, San Mateo, and Santa Clara counties. 

Fishing is an existing use on the Refuge and will continue to be allowed from boats in the open 

waters and navigable sloughs of southern San Francisco Bay. To protect harbor seals, boating has 

been prohibited on Mallard Slough from March 1 – August 31 and on Mowry Slough and 

Steinberger Slough from March 15 – June 15th. The Refuge’s managed ponds and tidal marshes 

are closed to fishing.

Shoreline-based fishing is also a popular visitor use on the Refuge which will continue. The public 

fishing pier in Fremont is open daily except on Thanksgiving, Christmas and New Year. However, 

the threatened western snowy plover occasionally nests along Marshlands Road. Between April 1 

and August 31, if nesting birds are found, Marshlands Road is closed to public vehicle traffic. On 

weekends when the closure is in effect, public access to the fishing pier is enabled via a free shuttle 

service. As a designated “Public Fishing Pier,” no fishing license is needed at this location. Access 

to the fishing sites on Coyote Creek at Coyote Creek Lagoon and Faber-Laumeister is provided by 

trails. 

Major fish species caught include rays, leopard sharks, sand sharks, white sturgeon, striped bass, 

and shiner surfperch. Based on annual reports over the last several years, there are an estimated 

3,700 fishing visits a year on the Refuge. Most anglers conduct catch-and-release fishing. Because 

of contaminants such as heavy metals in the Bay, an Environmental Health Hazard Assessment 

advises anglers to limit the amount of Bay fish that is eaten. Warning signs at the Dumbarton 

Fishing Pier and at Coyote Creek Lagoon explain the hazards in Korean, Spanish, Cambodian, 

Chinese, Vietnamese, and English.

Every year during National Wildlife Refuge Week, a special event is hosted on the Refuge to 

introduce the public to fishing. Bait and tackle for up to 50 people are provided allowing each 

C-88
participant to learn how to use a fishing rod along with the safety and ethics of fishing and what 

they can do to protect San Francisco Bay. 

Access for fishing on the Refuge will be expanded to provide additional shoreline opportunities. 

Materials such as brochures and wayside exhibits for hunting and fishing programs that convey 

Refuge messages would be developed or updated. A small fishing platform at Coyote Creek and 

Faber-Laumeister would be designed and installed. Shoreline fishing access to Alviso Slough 

(near Pond A9) would be implemented if determined feasible. The Marshlands Road fishing pier 

would be updated, including renovating the fish cleaning station.

Availability of Resources: Additional funds for construction of the new fishing platforms at 

Coyote Creek and Faber-Laumeister, updating the existing fishing pier and establishing the 

shoreline fishing opportunity on Alviso Slough near Pond A9 will be necessary. Funding for 

updated fishing and boating brochures will also be required. These funds would be sought though 

the existing National Wildlife Refuge appropriations. Grants and other funding sources will also 

be sought. Additional Refuge law enforcement and maintenance staff funding is needed for 

existing and proposed expanded fishing opportunities.

 

Item One-Time Cost Annual Costs

Fishing platform at Faber-Laumeister $300,000 $1,000

Fishing platform at Coyote Creek $300,000 $1,000

Fishing access at Alviso Slough near 

A9

$35,000 $1,000

Update fishing pier, fish cleaning 

stations, interpretive panels, etc.

$200,000 $2,000

Fishing and boating brochures, 

signage

$20,000 $2,000

Maintenance Staff (0.1 FTE) N/A $6,500

Refuge Law Enforcement (0.1 FTE) N/A $6,500

TOTAL $855,000 $20,000

Anticipated Impacts: 

The proposed use would not adversely impact sensitive fish species in the South Bay because of 

State fishing regulations would be enforced. In the South Bay, two species (Distinct Population 

Segments [DPS]) of fish are listed under the federal Endangered Species Act: Central California 

Coast steelhead DPS (Oncorhynchuse mykiss) and the North American green sturgeon southern 

DPS (Acipenser medirostris). Fishermen will be required to adhere to all California Fish and 

Game regulations. These regulations are designed to protect these and other sensitive species 

from impacts due to fishing.

Fishing will be limited to sloughs, open water, and designated facilities. Potential impacts to 

wildlife may occur through the use of boating to facilitate fishing. Individual animals may be 

disturbed by human contact to varying degrees. Studies have shown that birds can be impacted by 

human activities when they are disturbed and flushed from feeding, resting, or nesting areas. 

Flushing, especially repetitive flushing, can strongly impact habitat use patterns of many bird 

species. Flushing from an area can cause birds to expend more energy, be deterred from using 

desirable habitat, affect resting or feeding patterns, and increase exposure to predation or cause 

birds to abandon sites with repeated disturbance (Smith and Hunt 1995). Migratory birds are 

observed to be more sensitive than resident species to disturbance (Klein 1989). 

C-89
Both motorized and non-motorized boating can alter wildlife behavior. Though motorized boats 

generally have a greater effect on wildlife, even non-motorized boat use can alter distribution, 

reduce use of particular habitats by waterfowl and other birds, alter feeding behavior and 

nutritional status, and cause premature departure from areas (Knight and Cole 1995). However, 

compared to motorboats, canoes and kayaks appear to have less disturbance effects on most 

wildlife species (DeLong 2002) and disturbance to birds in general is reduced when boats travel at 

or below the 5 mile per hour speed limit.

Boating, including that associated with fishing, can disturb sensitive species during nesting season. 

This is particularly true in areas were boat traffic in the narrow Mallard Slough. Boating can 

negatively affect harbor seals (Phoca vitulina) during their sensitive pupping season. To prevent 

negative effects from boating, the following existing area closures are in effect: Mallard Slough, 

March 1 – August 31 and on Mowry Slough and Steinberger Slough, March 15 – June 15. The 

Refuge’s managed ponds are also closed to fishing due to the limited potential to catch recreational 

fish and high potential to disturb large concentrations of birds using these ponds.

Discarded fishing line and other fishing litter can entangle migratory birds and other wildlife and 

cause injury or death (Thompson 1969, Gregory 1991). 

Construction of new fishing facilities, signage, other associated infrastructure as well as the 

renovation of the fishing pier will result in loss of habitat and temporary disturbance to wildlife. 

Localized dust and noise will be created from construction operations, but should have negligible 

air quality impacts. The facilities, signage, and other associated infrastructure will be placed in 

sparsely vegetated (non-sensitive) areas near established or designated public trails to minimize 

loss of vegetation. Total construction footprint for new fishing infrastructure is expected to be less 

than 0.5 acre. In the long-term, use of the new fishing facilities will reduce existing impacts to the 

shoreline and vegetation that result from uncontrolled trampling of these areas by fishermen. The 

facilities will be small (accommodating no more than 20 people at a time) and installed in locations 

that avoid sensitive wildlife habitat. Additional signage would be installed to encourage visitors to 

limit their disturbance to wildlife and properly dispose of litter.

Overall, the proposed use of fishing is not expected to impact the ability of the Refuge to protect 

diverse tidal marsh, seasonal wetland habitats and adjacent transitional uplands critical to the 

needs of migratory birds and endangered species. Signage will be used to identify closed areas and 

deter entry into sensitive wildlife habitat and restrictions will be enforced. 

Public Review and Comment: 

Public review and comments were solicited in conjunction with distribution of the Draft CCP/EA 

for Don Edwards San Francisco Bay NWR, released in May 2012. One commenter requested that 

further analysis on boating impacts to habitat, such as increased fishing debris. Fishing debris, 

such as discarded fishing line, was mentioned in the “Anticipated Impacts” section.

Determination: 

_______ Use is Not Compatible

___X___ Use is Compatible with Stipulations

C-90
The following stipulations are required to ensure compatibility:

• Fishing and boating brochures and signage will be developed to inform users of regulations 

and etiquette to reduce wildlife disturbance. 

• Boats engaging in fishing must adhere to the California Boating Law. This information will 

be available to the public at appropriate access points on the Refuge, the headquarters 

visitor center, Alviso Environmental Educational Center and via the Refuge’s web site.

• Fishing and boating brochures, and signage will be developed to inform users of 

regulations and etiquette to reduce wildlife disturbance. A “Boating on the Refuge” 

brochure will be updated and made available to the public at the Refuge Office in Fremont, 

Alviso Environmental Education Center, and on the Refuge website. Information provided 

in this brochure will include no-wake speed limits, seasonal or specific area closures, and a 

map of trails in the adjacent sloughs.

• The following areas will be closed to boating and fishing: Mallard Slough, March 1 – August 

31 and Mowry Slough and Steinberger Slough, March 15 – June 15.

• When endangered or threatened nesting birds are found on or nearby, Marshlands Road 

will be closed to public vehicle traffic, April 1- August 31. 

• Monitoring of habitat in all areas where fishing occurs will take place during biological 

surveys for other species. If habitat or wildlife disturbance is determined to be 

detrimental, modifications to this use will be made to assure fishing on the Refuge is 

compatible.

• Increased law enforcement will be needed to ensure compliance with all state and federal 

regulations.

Justification: The National Wildlife Improvement Act of 1997 (Pub. L. 105-57) identifies six 

legitimate and appropriate uses of wildlife refuges: hunting, fishing, wildlife observation and 

photography, and environmental education and interpretation. Where these uses have been 

determined compatible, they are to receive enhanced consideration over other uses in planning and 

management. 

These uses have been determined compatible because fishing will not materially interfere with or 

detract from unit purposes. Fishing would allow the visiting public to enjoy, experience, and learn 

about native fish and plants in these unique and rare habitats of the South Bay. Concerns about 

protecting rare native plants and animals, and the overall integrity of the marsh ecosystem, 

require that fishing opportunities be limited to the open waters, navigable sloughs, and fishing 

facilities of the Refuge at this time. 

Mandatory Reevaluation Date (provide month and year):

___X___ Mandatory 15-Year Reevaluation Date (for priority public uses)

_______ Mandatory 10-Year Reevaluation Date (for all uses other than priority 

public uses)

NEPA Compliance for Refuge Use Decision (check one below):

______Categorical Exclusion without Environmental Action Statement

______Categorical Exclusion and Environmental Action Statement

C-91
__X___Environmental Assessment and Finding of No Significant Impact

______Environmental Impact Statement and Record of Decision

References Cited:

DeLong, A. 2002. Managing Visitor Use & Disturbance of Waterbirds. A Literature Review of 

Impacts and Mitigation Measures.

Gregory, M.R. 1991. The Hazards of Persistent Marine Pollution: Drift Plastics and Conservation 

Islands. J. Royal Soc. New Zealand 21(2): 83-100.

Klein, M. 1989. Effects of high levels of human visitation on foraging waterbirds at J. N. "Ding" 

Darling National Wildlife Refuge, Sanibel Florida. Master’s thesis. Gainesville, Florida: 

University of Florida.

Knight, R.L. and D.N. Cole. 1995. Wildlife responses to recreationists. Pages 71-79 in R.L. 

Knight and K.J. Gutzwiller, eds. Wildlife and Recreationists: coexistence through management 

and research. Island Press, Washington, D.C. 372 pp.

Smith, L. and J.D. Hunt. 1995. Nature tourism: impacts and management. Pp. 203-219 in Knight, 

R.L.; Gutzwiller, K.J. (Wildlife and recreationists: coexistence through management and 

research, eds.). Island Press, Washington, D.C.

Thompson, J.D. 1969. Feeding behavior of diving ducks on Keokuk Pool, Mississippi River. M.S. 

Thesis, Iowa State Univ., Ames. 79pp.

C-92


Appendix D. Refuge Plant List

Don Edwards San Francisco Bay National Wildlife Refuge Plant List

D-1

Family Scientific name Common name Native/Non-Native

Aceraceae Acer negundo var. californicum California box elder Native

Aizoaceae Mesembryanthemum crystallinum crystalline iceplant non-native

Aizoaceae Mesembryanthemum nodiflorum slenderleaf iceplant non-native

Aizoaceae Tetragonia tetragonioides New Zealand spinach non-native

Amaranthaceae Amaranthus spp. amaranthus spp. non-native

Anacardiaceae Rhus integrifolia lemonade berry native

Anacardiaceae Schinus molle Peruvian peppertree non-native

Anacardiaceae Toxicodendron diversilobum Pacific poison oak native

Apiaceae Anthriscus caucalis Bur chervil non-native

Apiaceae Apium graveolens var. dulce Wild celery non-native

Apiaceae Conium maculatum poison hemlock non-native

Apiaceae Eryngium aristulatum coyote thistle native

Apiaceae Foeniculum vulgare fennel non-native

Apiaceae Lomatium caruifolium caraway-leaved lomatium native

Apiaceae Lomatium utriculatum common lomatium native

Apiaceae Sanicula bipinnatifida purple sanicle native

Apocynaceae Vinca major periwinkle non-native

Araceae Zantedeschia aethiopica calla lily non-native

Araceae Arum italicum Italian lords and ladies non-native

Araliaceae Hedera helix English ivy non-native

Arecaceae Washingtonia robusta Mexican fan palm non-native

Arecaceae Phoenix canariensis Canary Island date palm non-native

Asteraceae Delairea odorata Cape ivy non-native

Asteraceae Achillea millefolium yarrow Native

Asteraceae Acroptilon repens Russian knapweed non-native

Asteraceae Ambrosia psilostachya western ragweed Native

Asteraceae Anaphalis margaritacea pearly everlasting native

Asteraceae Anthemis cotula stinking chamomile non-native

Asteraceae Artemisia douglasiana mugwort Native

Asteraceae Artemisia californica California sagebrush native

Asteraceae Baccharis douglasii salt marsh baccharis Native

Asteraceae Baccharis pilularis coyote brush native

Asteraceae Calendula arvensis field marigold non-native

Asteraceae Carduus pycnocephalus Italian thistle non-native

Asteraceae Carduus tenuiflorus Slender-flowered thistle non-native

Asteraceae Centaurea calcitrapa purple starthistle non-native

Asteraceae Centaurea maculosa spotted knapweed non-native

Asteraceae Centaurea melitensis tocolote non-native

Asteraceae Centaurea solstitialis yellow starthistle non-native

Asteraceae Centromadia pungens ssp. pungens common tarweed native

Asteraceae Chamomilla suaveolens pineapple weed non-native
Don Edwards San Francisco Bay National Wildlife Refuge Plant List

D-2

Family Scientific name Common name Native/Non-Native

Asteraceae Cirsium vulgare bull thistle non-native

Asteraceae Cotula australis Australian waterbuttons non-native

Asteraceae Cotula coronopifolia brass buttons non-native

Asteraceae Dittrichia graveolens stinkwort non-native

Asteraceae Encelia farinosa brittle bush native

Asteraceae Eriophyllum confertiflorum golden yarrow Native

Asteraceae Eriophyllum lanatum wooly sunflower Native

Asteraceae Eriophyllum staechadifolium lizard tail native

Asteraceae Euthamia occidentalis western goldenrod Native

Asteraceae Gnaphalium luteo-album everlasting cudweed non-native

Asteraceae Grindelia stricta gum plant native

Asteraceae Hemizonia congesta Hayfield tarweed native

Asteraceae Hemizonia pungens Common tarweed native

Asteraceae Hypochaeris glabra smooth cat's ear non-native

Asteraceae Hypochaeris radicata rough cat's ear non-native

Asteraceae Jaumea carnosa jaumea native

Asteraceae Lactuca saligna willow-leaf lettuce non-native

Asteraceae Lactuca serriola prickly lettuce non-native

Asteraceae Lasthenia conjugens Contra Costa goldfields native (fed endangered, CNPS 1B.1)

Asteraceae Lasthenia glaberrima smooth goldfields native

Asteraceae Lasthenia glabrata yellowray goldfields native

Asteraceae Layia platyglossa tidy tips Native

Asteraceae Madia sativa coast tarweed Native

Asteraceae Picris echioides bristly oxtongue non-native

Asteraceae Psilocarphus brevissimus woolly marbles native

Asteraceae Psilocarphus oregonus Oregon woolly-marbles native

Asteraceae Senecio vulgaris common groundsel non-native

Asteraceae Silybum marianum blessed milkthistle non-native

Asteraceae Sonchus asper spiny sowthistle non-native

Asteraceae Sonchus oleraceus common sow thistle non-native

Asteraceae Symphyotrichum chilense Pacific aster Native

Asteraceae Taraxacum officinale dandelion non-native

Asteraceae Tragopogon porrifolius purple salsify non-native

Asteraceae Xanthium spinosum spiny cockleburr non-native

Boraginaceae Amsinckia menziesii var. intermedia fiddleneck native

Boraginaceae Heliotropium curassavicum seaside heliotrope native

Boraginaceae Myosotis latifolia forget-me-not non-native

Boraginaceae Myosotis sylvatica woodland forget-me-not non-native

Boraginaceae Plagiobothrys bracteatus bracted popcornflower native

Boraginaceae Plagiobothrys humistratus dwarf popcornflower native

Boraginaceae Plagiobothrys stipitatus var. micranthus Stalked popcornflower native
Don Edwards San Francisco Bay National Wildlife Refuge Plant List

D-3

Family Scientific name Common name Native/Non-Native

Boraginaceae Plagiobothrys leptocladus alkali popcornflower native

Brassicaceae Brassica nigra black mustard non-native

Brassicaceae Brassica rapa field mustard non-native

Brassicaceae Capsella bursa-pastoris shepherd's purse non-native

Brassicaceae Cardamine hirsuta hairy bittercress non-native

Brassicaceae Cardaria draba hoary cress non-native

Brassicaceae Hirschfeldia incana short podded mustard non-native

Brassicaceae Lepidium latifolium perennial pepperweed non-native

Brassicaceae Lepidium oxycarpum forked pepperweed native

Brassicaceae Raphanus sativus radish non-native

Brassicaceae Sibara virginica common rock cress native

Brassicaceae Sinapis arvensis charlock mustard non-native

Brassicaceae Sisymbrium orientale oriental mustard non-native

Callitrichaceae Callitriche marginata California water starwort native

Campanulaceae Downingia pulchella flatface downingia native

Caprifoliaceae Lonicera hispidula var. vacillans California honeysuckle native

Caprifoliaceae Sambucus nigra ssp. Cerulea blue elderberry Native

Caprifoliaceae Symphoricarpos albus var. laevigatus Snowberry native

Caryophyllaceae Cerastium arvense field chickweed native

Caryophyllaceae Cerastium glomeratum mouse-ear chickweed non-native

Caryophyllaceae Spergularia macrotheca sticky sandspurry native

Caryophyllaceae Spergularia marina salt sandspurry native

Caryophyllaceae Stellaria media common chickweed non-native

Chenopodiaceae Atriplex depressa brittlescale native (rare) CNPS 1B.2

Chenopodiaceae Atriplex fruticulosa ball saltbush native

Chenopodiaceae Atriplex hortensis garden orache non-native

Chenopodiaceae Atriplex patula fat hen native

Chenopodiaceae Atriplex semibaccata Australian saltbush non-native

Chenopodiaceae Atriplex triangularis spearscale native

Chenopodiaceae Bassia hyssopifolia five horn bassia non-native

Chenopodiaceae Beta vulgaris common beet non-native

Chenopodiaceae Chenopodium album lamb's quarters non-native

Chenopodiaceae Salicornia europaea glasswort native

Chenopodiaceae Salicornia virginica salt marsh pickleweed native

Chenopodiaceae Salsola soda opposite-leaf Russian thistle non-native

Chenopodiaceae Salsola tragus Russian thistle non-native

Chenopodiaceae Suaeda californica California sea-blite native (fed endangered, CNPS 1B.1)

Chenopodiaceae Suaeda moquinii bush seep-weed native

Chenopodiaceae Salicornia subterminalis Parish's pickleweed native

Convolvulaceae Convolvulus arvensis field bindweed non-native

Convolvulaceae Cressa truxillensis alkali weed native
Don Edwards San Francisco Bay National Wildlife Refuge Plant List

D-4

Family Scientific name Common name Native/Non-Native

Cornaceae Cornus sericea American dogwood native

Crassulaceae Crassula aquatica water pygmy-weed native

Crassulaceae Crassula connata sand pygmy-weed native

Cuscutaceae Cuscuta salina salt marsh dodder native

Cyperaceae Carex praegracilis field sedge Native

Cyperaceae Eleocharis acicularis var. acicularis needle spikerush native

Cyperaceae Eleocharis macrostachya pale spikerush native

Cyperaceae Schoenoplectus acutus var. occidentalis tule Native

Cyperaceae Bolboschoenus robustus alkali bulrush Native

Cyperaceae Schoenoplectus californicus California Bulrush native

Cyperaceae Bolboschoenus maritimus maritime tule native

Dipsacaceae Dipsacus sativus Fuller's teasel non-native

Ericaeae Arctostaphylos spp. manzanita native

Euphorbiaceae Croton setigerus dove weed native

Euphorbiaceae Euphorbia esula leafy spurge non-native

Euphorbiaceae Euphorbia helioscopia madwoman's milk non-native

Euphorbiaceae Euphorbia oblongata eggleaf spurge non-native

Euphorbiaceae Euphorbia peplus petty spurge non-native

Euphorbiaceae Chamaesyce prostrata prostrate spurge non-native

Fabaceae Acacia baileyana Cootamundra wattle non-native

Fabaceae Acacia dealbata silver wattle non-native

Fabaceae Acacia longifolia golden wattle non-native

Fabaceae Acacia melanoxylon black acacia non-native

Fabaceae Acacia retinodes everblooming acacia non-native

Fabaceae Astragalus tener alkali milk vetch native

Fabaceae Genista monspessulana french broom non-native

Fabaceae Lotus corniculatus bird’s-foot trefoil non-native

Fabaceae Lotus purshianus lotus Native

Fabaceae Lotus scoparius deerweed native

Fabaceae Lupinus albifrons silver lupine native

Fabaceae Lupinus bicolor lupine native

Fabaceae Lupinus succulentus arroyo lupine Native

Fabaceae Medicago polymorpha California burclover non-native

Fabaceae Melilotus indicus annual yellow sweetclover non-native

Fabaceae Melilotus officinalis yellow sweetclover non-native

Fabaceae Trifolium barbigerum bearded clover native

Fabaceae Trifolium depauperatum var. amplectens pale sack clover native

Fabaceae Trifolium depauperatum var. depauperatum dwarf sack clover native

Fabaceae Trifolium depauperatum var. hydrophilum water sack clover native (rare) CNPS 1B.2

Fabaceae Trifolium fucatum bull clover native

Fabaceae Trifolium hirtum rose clover non-native
Don Edwards San Francisco Bay National Wildlife Refuge Plant List

D-5

Family Scientific name Common name Native/Non-Native

Fabaceae Trifolium incarnatum crimson clover non-native

Fabaceae Trifolium variegatum variegated clover native

Fabaceae Trifolium willdenovii tomcat clover Native

Fabaceae Vicia sativa spring vetch non-native

Fabaceae Vicia sativa ssp. sativa common vetch non-native

Fabaceae Vicia villosa hairy vetch non-native

Fagaceae Quercus agrifolia coast live oak native

Fagaceae Quercus douglasii blue oak Native

Frankeniaceae Frankenia salina Alkali heath native

Garryaceae Garrya elliptica coast silk-tassel bush native

Geraniaceae Erodium botrys broad-leaf filaree non-native

Geraniaceae Erodium cicutarium redstem filaree non-native

Geraniaceae Erodium moschatum whitestem filaree non-native

Geraniaceae Geranium carolinianum Carolina geranium native

Geraniaceae Geranium dissectum cutleaf geranium non-native

Geraniaceae Geranium molle crane's bill geranium non-native

Grossulariaceae Ribes sanguineum red-flowering currant native

Grossulariaceae Ribes speciosum fuschia-flowered gooseberry native

Hippocastanaceae Aesculus californica California buckeye native

Hydrophyllaceae Phacelia ciliata Great Valley phacelia native

Iridaceae Sisyrinchium bellum Blue-eyed grass native

Iridaceae Sisyrinchium californicum golden-eyed grass native

Isoetaceae Isoetes sp. quillwort native

Juncaceae Juncus ambiguus seaside toad rush native

Juncaceae Juncus balticus Baltic rush native

Juncaceae Juncus kelloggii kellogg dwarf rush native

Juncaginaceae Lilaea scilloides flowering-quillwort native

Lamiaceae Lamium amplexicaule henbit non-native

Lamiaceae Marrubium vulgare white horehound non-native

Lamiaceae Salvia mellifera black sage native

Lamiaceae Salvia spathacea hummingbird Sage native

Lamiaceae Stachys ajugoides hedge nettle native

Liliaceae Agave deserti desert agave native

Liliaceae Brodiaea elegans harvest brodiaea native

Liliaceae Brodiaea terrestris ssp. terrestris dwarf brodiaea native

Liliaceae Chlorogalum pomeridianum soap plant native

Liliaceae Dichelostemma capitatum blue dicks native

Liliaceae Muilla maritima common muilla native

Lythraceae Lythrum hyssopifolium Hyssop's loosestrife non-native

Malvaceae Malacothamnus fremontii Fremont mallow native

Malvaceae Malva neglecta common mallow non-native
Don Edwards San Francisco Bay National Wildlife Refuge Plant List

D-6

Family Scientific name Common name Native/Non-Native

Malvaceae Malva nicaeensis bull mallow non-native

Malvaceae Malva Parviflora cheeseweed mallow non-native

Malvaceae Malvella leprosa alkali mallow native

Marsiliaceae Pilularia americana pillwort native

Moraceae Ficus carica edible fig non-native

Myoporaceae Myoporum laetum myoporum non-native

Myrtaceae Eucalyptus camaldulensis red gum non-native

Myrtaceae Eucalyptus globulus Tasmanian blue gum non-native

Myrtaceae Eucalyptus polyanthemos silver dollar gum non-native

Myrtaceae Eucalyptus rudis western Australian floodedgum non-native

Oleaceae Olea europaea olive non-native

Onagraceae Camissonia subacaulis long-leaved suncup native

Onagraceae Epilobium brachycarpum willow herb native

Onagraceae Epilobium canum California fuchsia native

Onagraceae Epilobium ciliatum fringed willowherb native

Onagraceae Epilobium cleistogamum cleistogamus boisduvalia

Onagraceae Epilobium minutum desert willow herb native

Onagraceae Camissonia ovata sun cup native

Onagraceae Oenothera elata ssp. hookeri Hooker's evening primrose Native

Oxalidaceae Oxalis pes-caprae bermuda buttercup non-native

Papaveraceae Dicentra formosa Western bleeding heart native

Papaveraceae Eschscholzia californica California poppy native

Papaveraceae Fumaria officinalis fumitory non-native

Plantaginaceae Plantago coronopus cutleaf plantain non-native

Plantaginaceae Plantago elongata annual coast plantago native

Plantaginaceae Plantago erecta California plantain native

Plantaginaceae Plantago lanceolata english plantain non-native

Platanaceae Platanus racemosa westernsycamore native

Plumbaginaceae Limonium californicum California sea lavender native

Plumbaginaceae Limonium ramosissimum Algerian sea lavendar non-native

Plumbaginaceae Plumbago auriculata Cape leadwort non-native

Poaceae Agrostis exarata* spike bentrgrass Native

Poaceae Alopecurus saccatus Pacific foxtail native

Poaceae Arundo donax giant reed non-native

Poaceae Avena barbata slender wild oat non-native

Poaceae Avena fatua wild oat non-native

Poaceae Bromus carinatus var. carinatus California brome native

Poaceae Bromus catharticus rescue grass non-native

Poaceae Bromus hordeaceus soft brome non-native

Poaceae Bromus madritensis ssp. Rubens red brome non-native

Poaceae Bromus tectorum downy brome non-native
Don Edwards San Francisco Bay National Wildlife Refuge Plant List

D-7

Family Scientific name Common name Native/Non-Native

Poaceae Cortaderia selloana pampasgrass non-native

Poaceae Crypsis schoenoides swamp pricklegrass non-native

Poaceae Cynodon dactylon bermudagrass non-native

Poaceae Dactylis glomerata orchard grass non-native

Poaceae Danthonia californica California oatgrass Native

Poaceae Deschampsia cespitosa tufted hairgrass Native

Poaceae Distichlis spicata saltgrass native

Poaceae Elytrigia spp. tall wheatgrass non-native

Poaceae Elymus glaucus blue wildrye Native

Poaceae Festuca arundinacea tall fescue non-native

Poaceae Festuca idahoensis Idaho fescue Native

Poaceae Festuca rubra red fescue Native

Poaceae Hordeum brachyantherum meadow barley native

Poaceae Hordeum depressum low barley native

Poaceae Hordeum marinum ssp. gussoneanum Mediterranean barley non-native

Poaceae Hordeum murinum ssp. leporinum mouse barley non-native

Poaceae Koeleria macrantha june grass Native

Poaceae Koeleria phleoides annual junegrass non-native

Poaceae Leymus triticoides creeping wild rye native

Poaceae Lolium multiflorum Italian ryegrass non-native

Poaceae Lolium perenne perennial rye grass non-native

Poaceae Nassella pulchra purple needlegrass native

Poaceae Parapholis incurva sickle grass non-native

Poaceae Pennisetum clandestinum kikuyugrass non-native

Poaceae Pennisetum setaceum crimson fountaingrass non-native

Poaceae Phalaris aquatica harding grass non-native

Poaceae Phragmites australis common reed non-native

Poaceae Piptatherum miliaceum smilo grass non-native

Poaceae Pleuropogon californicus semaphore grass native

Poaceae Poa annua snnual bluegrass non-native

Poaceae Poa pratensis Kentucky bluegrass non-native

Poaceae Poa secunda ssp. secunda one-sided bluegrass native

Poaceae Polypogon monspeliensis rabbitfoot grass non-native

Poaceae Puccinellia maritima seaside alkaligrass non-native

Poaceae Puccinellia simplex California alkaligrass native

Poaceae Spartina alterniflora hybrids spartina hybrids non-native

Poaceae Spartina foliosa California cord grass native

Poaceae Vulpia bromoides European foxtail fescue non-native

Poaceae Vulpia microstachys small fescue Native

Poaceae Vulpia myuros rat-tail fescue non-native

Poaceae Bromus diandrus ripgut brome non-native
Don Edwards San Francisco Bay National Wildlife Refuge Plant List

D-8

Family Scientific name Common name Native/Non-Native

Polemoniacea Navarretia prostrata prostrate navarettia native (rare)CNPS 1B.1

Polemoniacea Navarretia squarrosa skunkweed Native

Polygonacae Rumex acetosella sheep sorrel non-native

Polygonacae Rumex crispus curly dock non-native

Polygonacae Rumex pulcher fiddle dock non-native

Polygonaceae Eriogonum nudum naked buckwheat Native

Polygonaceae Eriogonum spp. buckwheat species native

Portulacaceae Claytonia perfoliata miner's lettuce native

Portulacaceae Montia fontana water chickweed native

Portulacaceae Portulaca oleracea common purslane non-native

Primulaceae Anagallis arvensis scarlet pimpernel non-native

Ranunculaceae Aquilegia eximia VanHoutte's columbine native

Ranunculaceae Myosurus minimus common mousetail native

Ranunculaceae Myosurus sessilis tiny mousetail native

Ranunculaceae Ranunculus californicus Califonria buttercup native

Rhamnaceae Ceanothus foliosus wavyleaf ceanothus native

Rhamnaceae Ceanothus gloriosus glory mat native

Rhamnaceae Ceanothus griseus Carmel ceanothus native

Rhamnaceae Ceanothus thyrsiflorus blueblossom native

Rhamnaceae Rhamnus californica California coffeeberry native

Rosaceae Heteromeles arbutifolia toyon native

Rosaceae Prunus ilicifolia holly-leaf cherry native

Rosaceae Rosa californica California wild rose native

Rosaceae Rubus armeniacus Himalayan blackberry non-native

Rosaceae Rubus ursinus California blackberry native

Rubiaceae Galium aparine common bedstraw native

Salicaceae Salix lasiolepis arroyo willow native

Scrophulariaceae Antirrhinum vexillo sp. foothillpenstemon native

Scrophulariaceae Castilleja densiflora dense flower owl's clover native

Scrophulariaceae Kickxia elatine sharp point fluvellin non-native

Scrophulariaceae Limosella acaulis broad-leaved mudwort native

Scrophulariaceae Mimulus aurantiacus sticky monkey flower native

Scrophulariaceae Mimulus cardinalis scarlet monkeyflower native

Scrophulariaceae Mimulus puniceus red bush monkeyflower native

Scrophulariaceae Scrophularia californica bee plant native

Scrophulariaceae Veronica anagallis-aquatica water speedwell non-native

Scrophulariaceae Veronica peregrina ssp. xalapensis purslane speedwell native

Scrophulariaceae Castilleja ambigua johnny-nip native

Solanaceae Nicotiana acuminata var. multiflora many flower tobacco non-native

Solanaceae Nicotiana glauca tree tobacco non-native

Solanaceae Solanum nigrum black nightshade non-native
Don Edwards San Francisco Bay National Wildlife Refuge Plant List

D-9

Family Scientific name Common name Native/Non-Native

Solanaceae Solanum rostratum buffalobur non-native

Tamaricaceae Tamarix parviflora tamarisk non-native

Typhaceae Typha latifolia cattail non-native

Urticaceae Urtica urens dwarf nettle non-native

Valerianaceae Centranthus ruber red valerian non-native

Zygophyllaceae Tribulus terrestris puncturevine non-native

Liliaceae Yucca Spanish banner native

Appendix E. Refuge Species List

Don Edwards San Francisco Bay National Wildlife Refuge Birds List

E: Endangered; T: Threatened; SSC: State Species of Concern

Common Name Scientific Name Federal State Occurrence Classification

Greater White-fronted Goose Anser albifrons native

Snow Goose Chen hyperborea native

Ross’s Goose Chen rossii native

Canada Goose Branta canadensis nests locally native

Cackling Goose Branta hutchinsii native

Brant Branta bernicla SSC native

Tundra Swan Cygnus columbianus native

Gadwall Anas strepera nests locally native

Eurasian Wigeon Anas penelope native

American Wigeon Anas americana native

Mallard Anas platyrhynchos nests locally native

Blue-winged Teal Anas discors native

Cinnamon Teal Anas cyanoptera nests locally native

Northern Shoveler Anas clypeata nests locally native

Northern Pintail Anas acuta nests locally native

Green-winged Teal Anas crecca native

Canvasback Aythya valisineria nests locally native

Redhead Aythya americana SSC native

Ring-necked Duck Aythya collaris native

Tufted Duck Aythya fuligula non-native

Greater Scaup Aythya marila native

Lesser Scaup Aythya affinis nests locally native

Surf Scoter Melanitta perspicillata native

White-winged Scoter Melanitta fusca native

Black Scoter Melanitta nigra native

Long-tailed Duck Clangula hyemalis native

Bufflehead Bucephala albeola native

Common Goldeneye Bucephala clangula native

Barrow’s Goldeneye Bucephala islandica native

Hooded Merganser Lophodytes cucullata native

Common Merganser Mergus merganser native

Red-breasted Merganser Mergus serrator native

Ruddy Duck Oxyura jamaicensis nests locally native

California Quail Callipepla californica native

Ring-necked Pheasant Phasianus colchicus nests locally non-native

Red-throated Loon Gavia stellata native

Pacific Loon Gavia pacifica native

Common Loon Gavia immer native

Pied-billed Grebe Podilymbus podiceps nests locally native

Horned Grebe Podiceps auritus native

Red-necked Grebe Podiceps grisegena native

Eared Grebe Podiceps nigricollis nests locally native

E-1
Don Edwards San Francisco Bay National Wildlife Refuge Birds List

E: Endangered; T: Threatened; SSC: State Species of Concern

Common Name Scientific Name Federal State Occurrence Classification

Western Grebe Aechmophorus occidentalis native

Clark’s Grebe Aechmophorus clarkii nests locally native

American White Pelican Pelecanus erythrorhynchos SSC native

Brown Pelican Pelecanus occidentalis native

Brandt’s Cormorant Phalacrocorax penicillatus native

Double-crested Cormorant Phalacrocorax auritus nests locally native

Pelagic Cormorant Phalacrocorax pelagicus native

American Bittern Botaurus lentiginosus native

Least Bittern Ixobrychus exilis SSC native

Great Blue Heron Ardea herodias nests locally native

Great Egret Ardea alba nests locally native

Snowy Egret Egretta thula nests locally native

Little Blue Heron Egretta caerulea native

Cattle Egret Bubulcus ibis nests locally native

Green Heron Butorides virescens native

Black-crowned Night-Heron Nycticorax nycticorax nests locally native

White-faced Ibis Plegadis chihi native

Turkey Vulture Cathartes aura native

Osprey Pandion haliaetus nests locally native

White-tailed Kite Elanus coeruleus SP nests locally native

Bald Eagle Haliaeetus leucocephalus E native

Northern Harrier Circus cyaneus SSC nests locally native

Sharp-shinned Hawk Accipiter striatus native

Cooper’s Hawk Accipiter cooperii native

Red-shouldered Hawk Buteo lineatus native

Red-tailed Hawk Buteo jamaicensis nests locally native

Ferruginous Hawk Buteo regalis native

Rough-legged Hawk Buteo lagopus native

Golden Eagle Aquila chrysaetos SP native

American Kestrel Falco sparverius nests locally native

Merlin Falco columbarius native

Peregrine Falcon Falco peregrinus nests locally native

Prairie Falcon Falco mexicanus native

California Black Rail Laterallus jamaicensis coturniculus T native

California Clapper rail Rallus longirostris obsoletus E E nests locally native

Virginia Rail Rallus limicola native

Sora Porzana carolina native

Common Moorhen Gallinula chloropus nests locally native

American Coot Fulica americana nests locally native

Sandhill Crane Grus canadensis native

Black-bellied Plover Pluvialis squatarola native

American Golden-Plover Pluvialis dominica native

E-2
Don Edwards San Francisco Bay National Wildlife Refuge Birds List

E: Endangered; T: Threatened; SSC: State Species of Concern

Common Name Scientific Name Federal State Occurrence Classification

Pacific Golden-Plover Pluvialis fulva native

Western Snowy Plover Charadrius alexandrinus nivosus T nests locally native

Semipalmated Plover Charadrius semipalmata native

Killdeer Charadrius vociferus nests locally native

Black-necked Stilt Himantopus mexicanus nests locally native

American Avocet Recurvirostra americana nests locally native

Greater Yellowlegs Tringa melanoleuca native

Lesser Yellowlegs Tringa flavipes native

Willet Catoptrophorus semipalmatus native

Wandering Tattler Heteroscelus incanus native

Spotted Sandpiper Actitis macularia native

Whimbrel Numenius phaeopus native

Long-billed Curlew Numenius americanus native

Marbled Godwit Limosa fedoa native

Ruddy Turnstone Arenaria interpres native

Black Turnstone Arenaria melanocephala native

Red Knot Calidris canutus native

Sanderling Calidris alba native

Semipalmated Sandpiper Calidris pusilla native

Western Sandpiper Calidris mauri native

Least Sandpiper Calidris minutilla native

Baird’s Sandpiper Calidris bairdii native

Pectoral Sandpiper Calidris melanotos native

Dunlin Calidris alpina native

Stilt Sandpiper Calidris himantopus native

Ruff Philomachus pugnax native

Short-billed Dowitcher Limnodromus griseus native

Long-billed Dowitcher Limnodromus scolopaceus native

Wilson’s Snipe Gallinago delicata native

Wilson’s Phalarope Phalaropus tricolor native

Red-necked Phalarope Phalaropus lobatus native

Red Phalarope Phalaropus fulicaria native

Parasitic Jaeger Stercorarius parasiticus native

Franklin’s Gull Larus pipixcan native

Bonaparte’s Gull Larus Philadelphia native

Heermann’s Gull Larus heermanni native

Mew Gull Larus canus native

Ring-billed Gull Larus delawarensis native

California Gull Larus californicus nests locally native

Herring Gull Larus argentatus native

Thayer’s Gull Larus thayeri native

Western Gull Larus occidentalis nests locally native

E-3
Don Edwards San Francisco Bay National Wildlife Refuge Birds List

E: Endangered; T: Threatened; SSC: State Species of Concern

Common Name Scientific Name Federal State Occurrence Classification

Glaucous-winged Gull Larus glaucescens native

Glaucous Gull Larus hyperboreus native

Sabine’s Gull Xena sabini native

Caspian Tern Sterna caspia nests locally native

Elegant Tern Sterna elegans native

Common Tern Sterna hirundo native

Forster’s Tern Sterna forsteri nests locally native

California Least Tern Sterna antillarum browni E E native

Black Tern Chlidonias niger native

Black Skimmer Rynchops niger SSC nests locally native

Common Murre Uria aalge native

Rock Dove Columba livia non-native

Mourning Dove Zenaida macroura nests locally native

Barn Owl Tyto alba nests locally native

Great Horned Owl Bubo virginianus native

Burrowing Owl Athene cunicularia SSC nests locally native

Short-eared Owl Asio flammeus SSC nests locally native

Vaux’s Swift Chaetura vauxi SSC native

White-throated Swift Aeronautes saxatalis native

Anna’s Hummingbird Calypte anna nests locally native

Rufous Hummingbird Selasphorus rufus native

Allen’s Hummingbird Selasphorus sasin native

Belted Kingfisher Ceryle alcyon native

Red-breasted Sapsucker Sphyrapicus ruber native

Nuttall’s Woodpecker Picoides nuttallii native

Downy Woodpecker Picoides pubescens native

Northern Flicker Colaptes auratus native

Western Wood-Pewee Contopus sordidulus native

Willow Flycatcher Empidonax traillii native

Pacific-slope Flycatcher Empidonax difficilis native

Black Phoebe Sayornis nigricans nests locally native

Say’s Phoebe Sayornis saya native

Ash-throated Flycatcher Myiarchus cinerascens native

Western Kingbird Tyrannus verticalis native

Loggerhead Shrike Lanius ludovicianus SSC nests locally native

Warbling Vireo Vireo gilvus native

Western Scrub-Jay Aphelocoma californica nests locally native

American Crow Corvus brachyrhynchos native

Common Raven Corvus corax nests locally native

Horned Lark Eremophila alpestris nests locally native

Purple Martin Progne subis native

Tree Swallow Tachycineta bicolor nests locally native

E-4
Don Edwards San Francisco Bay National Wildlife Refuge Birds List

E: Endangered; T: Threatened; SSC: State Species of Concern

Common Name Scientific Name Federal State Occurrence Classification

Violet-green Swallow Tachycineta thalassina native

Northern Rough-winged Swallow Stelgidopteryx serripennis native

Bank Swallow Riparia riparia T native

Cliff Swallow Petrochelidon pyrrhonota nests locally native

Barn Swallow Hirundo rustica nests locally native

Chestnut-backed Chickadee Poecile rufescens native

Bushtit Psaltriparus minimus nests locally native

Rock Wren Salpinctes obsoletus native

Bewick’s Wren Thryomanes bewickii nests locally native

House Wren Troglodytes aedon native

Marsh Wren Cistothorus palustris nests locally native

Golden-crowned Kinglet Regulus satrapa native

Ruby-crowned Kinglet Regulus calendula native

Blue-gray Gnatcatcher Polioptila caerulea native

Swainson’s Thrush Catharus ustulatus native

Hermit Thrush Catharus guttatus native

American Robin Turdus migratorius native

Varied Thrush Ixoreus naevius native

Northern Mockingbird Mimus polyglottos nests locally native

Sage Thrasher Oreoscoptes montanus native

European Starling Sturnus vulgaris non-native 

American Pipit Anthus rubescens native

Cedar Waxwing Bombycilla cedrorum native

Orange-crowned Warbler Vermivora celata native

Nashville Warbler Vermivora ruficapilla native

Yellow Warbler Dendroica petechia SSC native

Yellow-rumped Warbler Dendroica coronata native

Townsend’s Warbler Dendroica townsendi native

Palm Warbler Dendroica palmarum native

Blackpoll Warbler Dendroica striata native

Northern Waterthrush Seiurus noveboracensis native

San Francisco common yellowthroat Geothlypis trichas sinuosa SSC nests locally native

Wilson’s Warbler Wilsonia pusilla native

Western Tanager Piranga ludoviciana native

Spotted Towhee Pipilo maculatus native

California Towhee Pipilo crissalis nests locally native

Bryant's savannah sparrow Passerculus sandwichensis alaudinus SSC nests locally native

Nelson’s Sharp-tailed Sparrow Ammodramus nelsoni native

Fox Sparrow Passerella iliaca native

Alameda song sparrow Melospiza melodia pusillula SSC nests locally native

Lincoln’s Sparrow Melospiza lincolnii native

Swamp Sparrow Melospiza georgiana native

E-5
Don Edwards San Francisco Bay National Wildlife Refuge Birds List

E: Endangered; T: Threatened; SSC: State Species of Concern

Common Name Scientific Name Federal State Occurrence Classification

White-throated Sparrow Zonotrichia leucophrys native

White-crowned Sparrow Zonotrichia atricapilla native

Golden-crowned Sparrow Zonotrichia atricapilla native

Dark-eyed Junco Junco hyemalis native

Black-headed Grosbeak Pheucticus melanocephalus native

Lazuli Bunting Passerina amoena native

Red-winged Blackbird Agelaius phoeniceus nests locally native

Tricolored Blackbird Agelaius tricolor SSC native

Western Meadowlark Sturnella neglecta nests locally native

Brewer’s Blackbird Euphagus cyanocephalus native

Brown-headed Cowbird Molothrus ater native

Hooded Oriole Icterus cucullatus native

Bullock’s Oriole Icterus bullockii nests locally native

House Finch Carpodacus mexicanus nests locally native

Lesser Goldfinch Carduelis psaltria native

American Goldfinch Carduelis tristis nests locally native

House Sparrow Passer domesticus nests locally non-native

Brown Booby Sula leucogaster accidental native

Magnificent Frigatebird Fregata magnificens accidental native

Glossy Ibis Plegadis falcinellus accidental native

Wild Turkey Meleagris gallopavo native

Black Oystercatcher Haematopus bachmani accidental native

Solitary Sandpiper Tringa solitaria accidental native

Hudsonian Godwit Limosa haemastica accidental native

Bar-tailed Godwit Limosa lapponica accidental native

Surfbird Aphriza virgata accidental native

Little Stint Calidris minuta accidental native

Sharp-tailed Sandpiper Calidris acuminata accidental native

Curlew Sandpiper Calidris ferruginea accidental native

Buff-breasted Sandpiper Tryngites subruficollis accidental native

Little Gull Larus minutus accidental native

Black-headed Gull Larus ridibundus accidental native

Lesser Black-backed Gull Larus fuscus accidental native

Slaty-backed Gull Larus schistisagus accidental native

Arctic Tern Sterna paradisaea accidental native

Ancient Murrelet Synthliboramphus antiquus accidental native

Pigeon Guillemot Cepphus columba accidental native

Band-tailed Pigeon Columba fasciata native

Chimney Swift Chaetura pelagica accidental native

Black-chinned Hummingbird Archilochus alexandri accidental native

Least Flycatcher Empidonax minimus accidental native

Dusky Flycatcher Empidonax oberholseri accidental native

E-6
Don Edwards San Francisco Bay National Wildlife Refuge Birds List

E: Endangered; T: Threatened; SSC: State Species of Concern

Common Name Scientific Name Federal State Occurrence Classification

Hammond’s Flycatcher Empidonax hammondii accidental native

Tropical Kingbird Tyrannus melancholicus accidental native

Cassin’s Kingbird Tyrannus vociferans accidental native

Hutton’s Vireo Vireo huttoni accidental native

Cassin's Vireo Vireo cassinii accidental native

White Wagtail Motacilla alba accidental native

American Redstart Setophaga ruticilla accidental native

Magnolia Warbler Dendroica magnolia accidental native

Yellow-breasted Chat Icteria virens SSC accidental native

Sage Sparrow Amphispiza belli accidental native

Chipping Sparrow Spizella passerina accidental native

Clay-colored Sparrow Spizella pallida accidental native

Brewer’s Sparrow Spizella breweri accidental native

Vesper Sparrow Pooecetes gramineus accidental native

Lark Sparrow Chondestes grammacus accidental native

Chestnut-collared Longspur Calcarius ornatus accidental native

Pine Siskin Spinus pinus accidental native

E-7
Don Edwards San Francisco Bay National Wildlife Refuge Mammal List

E: Endangered; FP: Fully Protected

Common Name Scientific Name Federal State Occurrence Classification

Virginia opossum Didelphis virginianus upland non-native

salt marsh wandering shrew Sorex vagrans halicoetes marsh native

Yuma myotis Myotis yumanensis all habitats native

Western red bats Lasirurs blossevillii all habitats native

Hoary bats Lasiurus cinereus all habitats native

Mexican free-tailed bat Tadarida brasiliensis all habitats native

Raccoon Procyon lotor all habitats native

Common muskrat Ondatra zibethicus all habitats native

Long-tailed weasel Mustela frenata all habitats native

Striped skunk Mephitis mephitis all habitats native

western spotted skunk Spilogale gracilis all habitats native

Gray fox Urocyon cinereoargenteus all habitats native

Red fox Vulpes vulpes all habitats non-native

Mountain lion Felis concolor FP all habitats native

Pacific harbor seal Phoca vitulina richardsi tidal sloughs native

California ground squirrel Spermophilus beecheyi upland native

Botta's pocket gopher Thomomys bottae upland native

Western harvest mouse Reithrodontomys megalotis all habitats native

Salt marsh harvest mouse Reithrodontomys raviventris 

raviventris E E marsh native

House mouse Mus musculus all habitats non-native

Deer mouse Peromyscus maniculatus all habitats native

California vole Microtus californicus all habitats native

Norway rat Rattus norvegicus all habitats non-native

Black rat Rattus rattus all habitats non-native

Brush rabbit Sylvilagus bachmani upland native

Audubon's cottontail Sylvilagus audubonii upland native

Black-tailed jackrabbit Lepus californicus upland native

E-8
Don Edwards San Francisco Bay National Wildlife Refuge Amphibian and Reptile List

T: Threatened; E: Endangered; SC: Species of Concern

Common Name Scientific Name Federal State Occurrence Classification

California tiger salamander Ambystoma californiense T E Known native

Arboreal salamander Aneides lugubris Possible native

California slender salamander Batrachoseps attenuatus Possible native

Pacific tree frog Pseudacris regilla Known native

Western fence lizard Sceloporus occidentalis Known native

Western skink Eumeces skiltonianus Possible native

Southern alligator lizard Elgaria multicarinata Known native

Gopher snake Pituophis melanoleuca Known native

Common garter snake Thamnophis sirtalis Known native

Western terrestrial garter snake Thamnophis elegans Known native

Western rattlesnakes Crotalus oreganus Known native

Western pond turtle Clemmys marmorata SC Known native

E-9
Don Edwards San Francisco Bay National Wildlife Refuge Fish List

T: Threatened; E: Endangered

Common Name Scientific Name Federal State Occurrence Classification

Leopard shark Triakis semifasciata present in tidal waters and ponds native

Soupfin shark Galeorhinus galeus present in tidal waters native

Brown smoothhound Mustelus henlei present in tidal waters and ponds native

Big skate Raja binoculata present in tidal waters native

Spiny dogfish Squalus acanthias present in tidal waters native

California skate Raja inornata present in tidal waters native

Bat ray Myliobatis californica present in tidal waters and ponds native

Green sturgeon Acipenser medirostris T present in tidal waters native

American shad Alosa sapidissima present in tidal waters non-native

Pacific herring Clupea pallasii present in tidal waters native

Threadfin shad Dorosma petenense present in tidal waters non-native

Pacific sardine Sardinops sagax present in tidal waters native

Northern anchovy Engraulis mordax present in tidal waters and ponds native

Chinook salmon Oncorhynchus tshawytscha E E present in tidal waters native

Steelhead (Central California Coast DPS) Oncorhynchus mykiss T present in tidal waters native

Longfin smelt Spirinchus thaleichthys T present in tidal waters native

Common carp Cyprinus carpio present in tidal waters non-native

Sacramento sucker Catostomus occidentalis occidentalis present in tidal waters native

Pacific whiting (hake) Merluccius productus present in tidal waters native

Plainfin midshipman Porichthys notatus present in tidal waters native

Rainwater killifish Lucania parva present in tidal waters and ponds non-native

Topsmelt Atherinops affinis present in tidal waters and ponds native

Mississippi silversides Menidia audens present in tidal waters and ponds non-native

Jacksmelt Atherinopsis californiensis present in tidal waters native

Threespine sticklebacks Gasterosteus aculeatus present in tidal waters and ponds native

Bay pipefish Syngnathus leptorhynchus present in tidal waters and ponds native

Brown rockfish Sebastes auriculatus present in tidal waters native

Bocaccio Sebastes paucispinis rare in tidal waters non-native

Calico rockfish Sebastes dalli rare in tidal waters native

Kelp greenling Hexagrammos decagrammus present in tidal waters native

Lingcod Ophiodon elongatus present in tidal waters native

Prickly sculpin Cottus asper present in tidal waters and ponds native

Pacific staghorn sculpin Leptocottus armatus present in tidal waters and ponds native

Cabezon Scorpaenichthys marmoratus rare in tidal waters non-native

Striped bass Morone saxatilis present in tidal waters and ponds non-native

Jackmackerel Trachurus symmetricus present in tidal waters native

White croaker Genyonemus lineatus present in tidal waters native

Shiner surfperch Cymatogaster aggregata present in tidal waters and ponds native

Barred surfperch Amphistichus argenteus present in tidal waters and ponds native

Yellowfin goby Acanthogobius flavimanus present in tidal waters and ponds non-native

Arrow goby Clevelandia ios present in tidal waters native

Longjaw mudsucker Gillichthys mirabilis present in tidal waters and ponds native

Cheekspot goby Ilypnus gilberti present in tidal waters native

Bay goby Lepidogobius lepidus present in tidal waters native

Chameleon goby Tridentiger trigonocephalus present in tidal waters and ponds non-native

E-10
Don Edwards San Francisco Bay National Wildlife Refuge Fish List

T: Threatened; E: Endangered

Shimofuri goby Tridentiger bifasciatus present in tidal waters and ponds non-native

Shokahaze goby Tridentiger barbatus present in tidal waters and ponds non-native

Pacific sanddab Citharichthys sordidus present in tidal waters native

Speckled sanddab Citharichthys stigmaeus present in tidal waters and ponds native

California halibut Paralichthys californicus present in tidal waters native

Rex sole Glyptocephalus zachirus rare in tidal waters native

Diamond turbot Hypsopsetta guttulata present in tidal waters and ponds native

English sole Parophrys vetulus present in tidal waters native

Starry flounder Platichthys stellatus present in tidal waters native

Curlfin sole Pleuronichthys decurrens present in tidal waters native

Sand sole Psettichthys melanostictus present in tidal waters native

E-11

Appendix F. Vegetation Map

E2

A5

A18

M3

M4

R1

M1

M2

E9

M6

N3

M8 M7

E1

A9

M5

N7

R4

A23

N4 N1

A3W

R3

A1

Outer Bair Island

M13

A7

A4

N3A

A8N

A14

E6A

E7

M9

A2W

A2E

A12

E6B

Middle Bair Island

SF2

E8

E6

E4

M10

E10

A22

A13

A19

A6

A11

E8A

N4A

Greco Island

E5

A10

A15

A16

N5

M12

R2

PP1 N2

N4Z

E14

E4C

N9

AB2

A21

E3C

N8

M11

E13

N2A

AB1

N1A

A17

E11

N6

E12

E5C

A8S

Inner Bair Island

E6C

A20

E1C

R5

E8X

A3N

N4B

S5

Sunnyvale Treatment Plant

Crystallizers

E2C

Cargill Redwood City Plant Site

San Jose

E15

E16

E14

Eden Landing

Ravenswood

·|}þ84 Alviso

%&'(280

Æþ101

·|}þ237

%&'(880

·|}þ84

S et ni berger Slough

Re dwood Creek

M t n. View S lo ugh

Stevens Creek

G u adalupe Slo ugh

A lviso Slough

C oyote Creek

Mowry Slough

Alameda Creek

Old Alameda Creek

·|}þ92

Westpoint Slough

Charles ton Slough

Artesian Slough

Newark Slough

Mt E den Creek

Newark

Belmont

Fremont

Hayward

Atherton

Woodside Stanford

Milpitas

San Mateo

Menlo Park

San Carlos

Union City

Foster City

Redwood City

East Palo Alto

Preliminary final habitat model - July 4th, 2010 (Ikonos). Map prepared by Brian Fulfrost on February 2nd, 2012 (bfaconsult@gmail.com)

0 1 2 Miles

Upland

Mustard

Alkali Grasses

Fresh Marsh

Bulrush

Cattail

Bulrush /- Cattail

Salt Marsh

Cordgrass

Saltgrass

Pickleweed - annual

Pickleweed - perennial

Pepperweed /- Pickleweed

Pepperweed

Jaumea (can also include pickleweed)

Gumplant (can also include pickleweed)

Alkali Heath (can also be spearscale)

Pickleweed /- Cordgrass

Brackish Marsh

Alkali Bulrush /- Pickleweed

Alkai Bulrush

Pepperweed /- Alkali Bulrush

Alkali Bulrush /- Spearscale

Other

wrack (including dead plants)

water

mud

mud w/ biofilm

bare earth

algae

Appendix G. Avian Use of Salt-Production and WildlifeManaged Ponds in the South Bay

G-1 

Avian use of salt-production and wildlife-managed ponds in the South Bay 

Adapted from: N. D. Athearn, J.Y. Takekawa, J.D. Bluso-Demers, J.M. Shinn, L. A. Brand, C.W. RobinsonNilsen, and C.M. Strong. 2011, in press. Monitoring Bird Distribution and Abundance to Inform Adaptive 

Management for Salt Pond Restoration in San Francisco Bay, California, USA. Hydrobiologia. 

Seventy-six South Bay ponds were sampled monthly October 2005- May 2009. Ponds ranged in 

size from 12 ha to 276 ha and varied in mean annual salinity from 15 g·l-1 to 271 g·l-1. U.S. 

Geological Survey and San Francisco Bay Bird Observatory observers conducted counts of all 

species of waterbirds. Surveys were conducted during daylight hours within 3 hours of the high 

tide, when the largest number of waterbirds was roosting in the ponds. Identified waterbirds 

were separated into guilds to examine differences among generalized groups in addition to 

differences among key species. These groups included ducks, shorebirds, shorebirds, 

phalaropes (a high salinity specialist shorebird), and piscivores (fish-eating birds; Table 1), 

although many more species were identified that did not conform to these groups. These 

groups were chosen because of their high pond use, and because of their diverse foraging 

strategies. Several additional representative species were chosen which were typically found in 

high densities on ponds relative to other Bay habitats: 1) eared grebe – grebes which foraged 

on water column invertebrates and considered a high-salinity specialist, 2) Forster’s terns –

representing colonially nesting birds including American avocets, black-necked stilts, Caspian 

and Forster’s terns that nest on islands and levees within the pond complexes, 3) California 

gulls - gulls that nest on islands, levees and dry ponds; now considered a nuisance species in the 

South Bay due to their expanding population. 

Ponds were grouped according to geographic location, and whether they were salt-production 

ponds (“Production”) or wildlife-managed ponds, and thus part of the South Bay Salt Pond 

Restoration Project management (“SBSPRP”; Figure 1). Takekawa et al. (2006) identified four 

salinity classes to classify trophic communities in ponds: brackish (0.5 – 30 g•l-1), and low 

salinity (31 – 80 g•l-1), mid salinity (81 – 150 g•l-1), and high salinity (>150 g•l-1). The following 

maps serve as a visual representation of this synthesized data set, with each guild or species 

map chosen for highest abundance of birds (Figures 2-8).

Table 1. Species and associated guilds counted on USGS and SFBBO surveys, October 2005 –

May 2009. 

Ducks 

American Green-winged Teal 

American Wigeon 

Blue-winged Teal 

Cinnamon Teal 

Domestic Mallard 

Eurasian Wigeon 

Gadwall 

Long-tailed Duck 

Mallard 

Northern Pintail 

Northern Shoveler 

Barrow's Goldeneye 

Bufflehead 

Canvasback 

Common Goldeneye 

Greater Scaup 

Lesser Scaup 

Redhead 
G-2 

Ring-necked Duck 

Ruddy Duck 

Surf Scoter 

Tufted Duck 

White-winged scoter 

Shorebirds 

American Avocet 

Black-bellied Plover 

Black Turnstone 

Black-necked Stilt 

Common Snipe 

Golden Plover 

Greater Yellowlegs 

Killdeer 

Long-billed Curlew 

Lesser Yellowlegs 

Marbled Godwit 

Pacific Golden-Plover 

Red Knot 

Ruff 

Ruddy Turnstone 

Spotted Redshank 

Stilt Sandpiper 

Surfbird 

Whimbrel 

Willet 

Baird's Sandpiper 

Dunlin 

Long-billed Dowitcher 

Least Sandpiper 

Pectoral Sandpiper 

Sanderling 

Short-billed Dowitcher 

Semipalmated Plover 

Semipalmated Sandpiper 

Snowy Plover 

Spotted Sandpiper 

Western Sandpiper 

Curlew Sandpiper 

Phalaropes 

Red Phalarope 

Red-necked Phalarope 

Wilson's Phalarope 

Piscivores 

American White Pelican 

Belted Kingfisher 

Brown Pelican 

Clark's Grebe 

Common Loon 

Common Merganser 

Double-crested Cormorant 

Hooded Merganser 

Pacific Loon 

Pied-billed Grebe 

Pelagic Cormorant 

Red-breasted Merganser 

Red-necked Grebe

Red-throated Loon 

Western Grebe 

Brandt's Cormorant 

California Gull 

Glaucous Gull 

Glaucous-winged Gull 

Herring Gull 

Mew Gull 

Ring-billed Gull 

Slaty-backed Gull 

Thayer's Gull 

Western Gull 

American Bittern 

Black-crowned Night Heron 

Cattle Egret 

Great Blue Heron 

Great Egret 

Green Heron 

Little Blue Heron 
G-3 

Snowy Egret 

Arctic Tern 

Black Skimmer 

Black Tern 

Caspian Tern 

Common Tern 

Elegant Tern 

Forster's Tern 

Least Tern 
G-4 

Figure 1: The seventy-six South Bay ponds were grouped according to geographic location, and whether they were saltproduction ponds (“Production”) or wildlife-managed ponds, and thus part of the South Bay Salt Pond Restoration Project 

management (“SBSPRP”).
G-5 

Figure 2: Average monthly abundance of ducks, winter 2006-2009. 
G-6 

Figure 3: Average monthly abundance of shorebirds, winter 2006-2009. 
G-7 

Figure 4: Average monthly abundance of phalaropes, summer 2006-2008. 
G-8 

Figure 5: Average monthly abundance of piscivores, winter 2006-2009. 
G-9 

Figure 6: Average monthly abundance of eared grebe, spring 2006-2009. 
G-10

Figure 7: Average monthly abundance of Forster’s tern, summer 2006-2008. 
G-11

Figure 8: Average monthly abundance of California gull, summer 2006-2008. 
G-12

Discussion 

The waterbird species that use the South Bay ponds are diverse in their foraging strategies and 

habitat needs, and these differences were reflected in the relative densities of waterbird 

groups examined at the different pond complexes. 

Bird Use of Pond Complexes 

Ducks were primarily found in the Alviso ponds, which were generally low in salinity and 

provided a range of depths. Alviso ponds had significantly higher densities of total and foraging 

ducks than all other systems, including both northern shovelers (dabbling ducks) and ruddy 

ducks (diving ducks), species regularly observed in high numbers on ponds during the winter in 

the estuary (Figure 2). 

Shorebirds were primarily found in low and mid salinity ponds at the Eden Landing complex, 

where saline-specialist invertebrates such as Ephydra spp. could be easily obtained. Shorebirds 

were a diverse group, but when not considering season, shorebirds had highest densities at the 

Eden Landing complex for both foraging and total birds. Relative use of Ravenswood ponds 

declined during fall, when the majority of ponds moved into the high salinity classification, 

while the majority of Eden Landing ponds remained in the low salinity classification. Eden 

Landing ponds were circulated with bay water, which may have prevented those ponds from 

becoming more concentrated in salts during the summer and fall. Although Newark ponds were 

similar in salinity to Eden Landing, sandpiper (and thus total shorebird) density at those ponds 

was low and restricted to a few ponds. Marbled godwits are larger shorebirds and were 

observed at similar densities in Newark ponds as in Eden Landing and Ravenswood ponds. This 

suggests that bird size (and perhaps water depth) is responsible for the distribution of 

shorebirds across ponds of similar salinity; however, foraging godwit density was lower in 

Newark ponds, so many godwits may have used these ponds for roosting rather than foraging 

(Figure 3). 

Phalaropes are present in the Bay during their migratory periods. Because they migrate earlier 

than many other species, their highest numbers are found in the South Bay in summer (during 

their “fall” migration). Phalaropes are a specialized shorebird and forage by swimming in tight 

circles. They feed on aquatic invertebrates including Artemia and Ephydra and are therefore 

found on the higher salinity ponds in Newark ponds and in one pond in Alviso (Figure 4). 

Piscivores were observed at highest densities in the Alviso and Mowry complexes, which were 

the lowest and highest salinity ponds. Because fish are only available in lower salinity ponds, 

bird use at the Mowry complex was likely limited to roosting, and foraging birds were primarily 

restrained to Alviso ponds, where foraging density was highest and pond salinity was lowest 

(Figure 5). 

Eared grebes, like shorebirds, were observed at highest densities in the low and mid salinity 

ponds. They were predominately present in the Newark complex, which had ponds in similar 

salinity classes as Eden Landing. Grebes feed on water column invertebrates such as Artemia
G-13

and Ephydra, which should be present in both pond complexes. However, Eden Landing ponds 

were shallow and used by shorebirds, whereas Newark ponds were deeper and used by grebes. 

Eared grebes were also found in local high densities in a few ponds in Alviso, where some ponds 

are managed as high salinity ponds for grebes and other saline-specialist bird species (Figure 6). 

However, abundance of grebes has declined in recent years (Takekawa et al., 2005). 

Colonial waterbirds nest in large numbers on islands and levees within the pond complexes. 

Forster’s terns preferentially choose these habitats over other available habitats (Strong et al. 

2004). Although colony locations change over time, some islands have been used consistently 

over the past few years (Figure 7). Double-crested cormorants, American avocets, Black-necked 

stilts, Black skimmers, Caspian terns, and California gulls also nest in colonies on the ponds. 

California gulls have consistently nested in some colonies over the past two decades; their 

numbers and colony locations have been expanding at the expense of other nesting species and 

they are considered a nuisance species in the South Bay (Figure 8).

Pond Salinity and Bird Use 

Pond salinity varied throughout the year, with lowest salinities typically occurring during the 

winter rainy season, and the highest salinities recorded during the drier months of summer and 

fall. This is the expected pattern in the Bay region, where summers are hot and dry favoring 

evaporation and concentration of salts within ponds. The Alviso complex, included in the 

SBSPRP area, had the highest proportion of brackish ponds overall – 48% of its ponds were 

brackish during fall and winter, and 56-60% of ponds were brackish during spring and summer. 

More ponds were at lower salinities during the spring and summer due to management 

practices. 

Brackish ponds support benthic invertebrates such as those used by shorebirds in shallow water 

and diving ducks in deeper water, and they also provide favorable conditions for birds that 

consume fish, which generally cannot survive in salinities > 80 g·l-1 (Takekawa et al., 2006). 

However, low to mid salinity ponds are particularly valuable for many shorebirds and other 

species that can forage on the dense populations of saline-specialist invertebrates Artemia and 

Ephydra that thrive there. 

Bird Use among Sites 

The abundance and species composition of macroinvertebrate prey is related to salinity, while 

the availability of prey to particular species of birds depends on depth (Velasquez 1992). Pond 

waters were generally well-mixed, so within-pond variation in bird abundance was a factor of 

pond topography rather than salinity. For example, distribution of eared grebes was likely due 

to a combination of moderately high salinity, providing the prey base in the pond, and sufficient 

depth, providing accessibility to prey. Ponds with appropriate salinity levels could not be used 

by eared grebes if they were too shallow to support a grebe’s method of foraging within the 

water column. Shorebirds were most abundant in ponds with similar salinity levels as eared 

grebes, but required ponds that were sufficiently shallow for wading. Topographic variability 

within a pond enabled these species to coexist, with shorebirds using shallow areas and grebes 

using deeper areas. Topographic variability in general allows use of ponds by a greater number 
G-14

of species and also retains the usability of ponds for single species during periods of water level 

changes. 
G-15

References 

C.M. Strong, Spear, L.B., T.P. Ryan. R.E. Dakin. 2004. Forster’s Tern, Caspian Tern, and California 

Gull Colonies in San Francisco Bay: Habitat Use, Numbers and Trends, 1982-2003. Waterbirds, 

27: 411-423. 

Takekawa, J.Y., A.K. Miles, D.H. Schoellhamer, B. Jaffe, N.D. Athearn, S.E. Spring, G.G. 

Shellenbarger, M.K. Saiki, F. Mejia & M.A. Lionberger. 2005. South Bay Salt Ponds Restoration 

Project Short-term Data Needs, 2003-2005. Unpublished Final Report, U. S. Geological Survey, 

Vallejo, CA, 270 pp. 

Takekawa, J.Y., A.K. Miles, D.H. Schoellhamer, N.D. Athearn, M.K. Saiki, W.D. Duffy, S. 

Kleinschmidt, G.G. Shellenbarger & C.A. Jannusch. 2006. Trophic structure and avian 

communities across a salinity gradient in evaporation ponds of the San Francisco Bay estuary. 

Hydrobiologia 567: 307–327.

Velasquez, C.R. 1992. Managing artificial saltpans as a waterbird habitat: species' response to 

water level manipulation. Colonial Waterbirds 15: 43–55.