U.S. Department of the Interior

U.S. Fish & Wildlife Service

Maui National Wildlife Refuge Complex

Milepost 6 Mokulele Highway

Kı ̄hei, Hawai‘i 96753

Phone: 808/875 1582

Fax: 808/875 2954

http://www.fws.gov

National Wildlife Refuge System Information

1 800/344 WILD

August 2011

The mission of the U.S. Fish & Wildlife Service

is working with others to conserve, protect, and

enhance fish, wildlife, and plants and their habitats

for the continuing benefit of the American people.

Front Cover Inset Photos Back Cover

Ae‘o Koloa ma ̄pu ‘Auku‘u

USFWS ©Tom Dove ©Kanalu Chock

Ko ̄lea

©Mike Walther
Ka Nu‘ukia no ka Pu‘uhonua Holoholona

Ma na ̄ lihikaha o ka ‘ao‘ao hema o na ̄ kahakai o Maui kahi e ulu ahewa nei na ̄ kaiaulu, 

eia ho‘i ne ̄ia wahi i ha ̄mama wale i ka nui; ‘a ̄ina a me ka wai e ko ̄kua ana ho‘i me na ̄ ‘a ̄ina 

kumu wai e ko ̄kua ana pu ho‘i i na ̄ ‘a ̄papa a me na ̄ kai i kapa ‘ia o Kea ̄lia Pond National 

Wildlife Refuge. Ma ̄lama ho‘i na ̄ ae‘o wa ̄wae loloa i ka ̄ la ̄kou mau manu pepe kalakoa a 

puhuluhulu i neia wahi nei, a e ‘imi no ho‘i na ̄ manu pepe ‘alae ke‘oke‘o me ko la ̄kou mai 

lae ‘ula‘alani i na ̄ ‘alae ke‘oke‘o ma ̄kua ma na ̄ pa ̄leilei ‘a ̄kea me na ̄ meakanu ulu pa ̄lialia. 

E pahe‘e ma ̄lie no ho‘i na ̄ manuwai ho‘oma ̄ka‘ika‘i li‘ili‘i ma ka wai a e lele kaha mai ho‘i 

na ̄ manu lihikai ma na ̄ lihiwai e ‘ai ana ho‘i i na ̄ mea’ai iwikuamo‘o ‘ole. E na ̄nea 

pu ̄ a ho‘omana‘o ho‘i na ̄ kama‘a ̄ina a me na ̄ malihini i ke ̄ia wahi ma ka 

pili pu ̄ hou ‘ana me na ̄ mea a ka ‘a ̄ina i ho‘oma ̄kaukau mua 

ai no la ̄kou ma ka pu‘uhona ma ̄lama holoholona 

‘oiwi a me ko la ̄kou kaianoho.

A Vision of Conservation

Refuge Vision

Nestled along Maui’s southern 

shore amidst growing communities, 

Kea ̄lia Pond National Wildlife Refuge is a 

welcome stretch of open space and water serving 

a vital watershed function to protect offshore reefs and 

waters. Within its mosaic of native wetland vegetation and 

open waters, thriving populations of long-legged ae‘o raise their 

camouflaged fluff-ball chicks, while ‘alae ke‘oke‘o chicks with their redorange downy heads and bills vie for their parents’ attention. Vacationing 

waterfowl peacefully glide through the waters, and shorebirds dart along the 

water’s edge, dining on spineless cuisine. As a vibrant national wildlife refuge, local 

residents and visitors alike find a means to reconnect with nature and play a significant 

role in protecting native wildlife and their habitats.

Comprehensive Conservation Plans provide 

long-term guidance for management decisions 

and set forth goals, objectives, and strategies needed to 

accomplish refuge purposes and identify the U.S. Fish and 

Wildlife Service’s best estimates of future needs. These plans detail 

program planning levels that are sometimes substantially above current 

budget allocations, and as such, are primarily used for strategic planning and 

program prioritization purposes. The plans do not constitute a commitment for staffing 

increases, operational and maintenance increases, or funding for future land acquisition. Kea ̄lia Pond Wetland 

©Jamison Carter
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan 

and Environmental Assessment 

Prepared by: 

U.S. Fish and Wildlife Service 

Maui National Wildlife Refuge Complex 

Milepost 6 Mokulele Highway (Hwy. 311) 

P.O. Box 1042 

Kīhei, HI 96753 

U.S. Fish and Wildlife Service 

Pacific Islands Planning Team 

300 Ala Moana Boulevard, Room 5-231 

Honolulu, Hawai‘i 96850 

August 2011 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Table of Contents i 

Table of Contents 

Readers’ Guide ................................................................................................................................... vii

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

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

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

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

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

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

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

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

 1.4.4 National Wildlife Refuge System Administration Act of 1966 ................................... 1-5 

 1.5 Refuge Establishment and Purposes .................................................................................. 1-6 

 1.5.1 Legal Significance of the Refuge Purpose ................................................................... 1-6 

 1.5.2 Refuge Establishment ................................................................................................... 1-6 

 1.5.3 Refuge Purpose ............................................................................................................. 1-7 

 1.6 Refuge Goals ......................................................................................................................... 1-7 

 1.7 Relationship to Previous and Future Refuge Plans .......................................................... 1-9 

 1.7.1 Future Planning ............................................................................................................ 1-9 

 1.8 Relationship to Ecosystem Planning Efforts ..................................................................... 1-9 

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

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

 1.9.2 Issues Outside the Scope of the Draft CCP ................................................................ 1-13 

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

 2.1 Considerations in Alternative Design ................................................................................ 2-1 

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

 2.3 Elements Common to All Alternatives............................................................................... 2-1 

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

 2.3.2 Interagency Coordination and Collaboration ............................................................... 2-2 

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

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

 2.3.5 Fire Management .......................................................................................................... 2-3 

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

 2.3.7 Adaptive Management .................................................................................................. 2-3 

 2.3.8 Integrated Pest Management ........................................................................................ 2-4 

 2.3.9 National Environmental Policy Act (NEPA) Compliance ........................................... 2-5 

 2.3.10 Law Enforcement ....................................................................................................... 2-5 

2.4 Alternative Descriptions ...................................................................................................... 2-6

 2.4.1 Alternative A: Continue Current Management Activities ........................................... 2-6 

 2.4.2 Alternative B: Restoration Focus ................................................................................ 2-8 

 2.4.3 Alternative C: Wetland Capacity Focus (Preferred Alternative) ................................. 2-9 

2.5 Goals, Objectives, Strategies, and Rationale ................................................................... 2-18 

 2.5.1 Goal 1 ......................................................................................................................... 2-19 

 2.5.2 Goal 2 ......................................................................................................................... 2-26 

 2.5.3 Goal 3 ......................................................................................................................... 2-28 

 2.5.4 Goal 4 ......................................................................................................................... 2-29 
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ii Table of Contents 

 2.5.5 Goal 5 ......................................................................................................................... 2-30 

 2.5.6 Goal 6 ......................................................................................................................... 2-34 

 2.5.7 Goal 7 ......................................................................................................................... 2-39 

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

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

 3.2 Climate .................................................................................................................................. 3-2 

 3.2.1 Global Climate Changes and Projections ..................................................................... 3-4

 3.2.2 Climate Change in Hawai‘i ............................................................................................ 3-5

 3.2.3 Sea Level Rise .............................................................................................................. 3-7 

 3.2.4 Ecological Responses to Climate Change .................................................................... 3-8 

 3.2.5 Climate Change at Keālia Pond .................................................................................... 3-9 

 3.3 Geology and Soils ............................................................................................................... 3-10

 3.3.1 Keālia Pond ................................................................................................................. 3-10

 3.3.2 Molokini ..................................................................................................................... 3-11

3.4 Hydrology ........................................................................................................................... 3-12

 3.4.1 Annual Hydrologic Cycle ........................................................................................... 3-12

 3.4.2 Water Quality of the Pond .......................................................................................... 3-18

3.5 Topography/Bathymetry ................................................................................................... 3-26

 3.6 Environmental Contaminants .......................................................................................... 3-30 

 3.6.1 Molokini Contaminants .............................................................................................. 3-31

3.7 Land Use ............................................................................................................................. 3-31 

 3.7.1 Previous Land Uses .................................................................................................... 3-33 

 3.7.2 Molokini Land Use ..................................................................................................... 3-34 

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

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

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

 4.2.1 Conservation Target Selection ..................................................................................... 4.4 

 4.3 Endangered Hawaiian Waterbirds .................................................................................... 4-7 

 4.3.1 Ae‘o (Himantopus mexicanus knudseni) or Hawaiian Stilt .......................................... 4-7 

 4.3.2 ‘Alae ke‘oke‘o (Fulica alai) or Hawaiian Coot ......................................................... 4-13 

 4.3.3 Koloa maoli (Anas wyvilliana) or Hawaiian Duck .................................................... 4-14 

 4.3.4 Nēnē (Branta sandvicensis) or Hawaiian Goose ....................................................... 4-14 

 4.4 Other Hawaiian Waterbirds ............................................................................................. 4-15 

 4.5 Migratory Waterfowl ........................................................................................................ 4-16 

 4.6 Migratory Shorebirds ........................................................................................................ 4-16 

 4.7 Seabirds .............................................................................................................................. 4-19 

 4.7.1 ‘Ua‘u kani (Puffinus pacificus) or Wedge-tailed Shearwater ..................................... 4-19 

 4.7.2 ‘Ou (Bulweris bulwerii) or Bulwer’s Petrel .............................................................. 4-19 

 4.7.3 Noio kōhā (Anous stolidus) or Brown Noddy ........................................................... 4-20 

 4.7.4 Noio (Anous minutus) or Black Noddy ...................................................................... 4-20 

 4.7.5 ‘Iwa (Fregata minor) or Great Frigatebird ................................................................. 4-20 

 4.8 Raptors................................................................................................................................ 4-21 

 4.9 Endangered Mammals ...................................................................................................... 4-21 

 4.10 Terrestrial Invertebrates ................................................................................................. 4-22 

4.11 Acquatic Invertebrates .................................................................................................... 4-22

4.12 Marine Reptiles ................................................................................................................ 4-23
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Table of Contents iii 

 4.12.1 Honu (Eretmochelys imbricate) or Hawaiian Green Turtle ..................................... 4-23 

 4.12.2 Honu ‘ea (Chelonia mydas) or Hawksbill Turtle ........................................................ 4-23

4.13 Native Plants ..................................................................................................................... 4-24 

4.14 Invasive Species ................................................................................................................ 4-25 

 4.14.1 Mammals .................................................................................................................. 4-26 

 4.14.2 Birds ......................................................................................................................... 4-28 

 4.14.3 Amphibians............................................................................................................... 4-28 

 4.14.4 Invertebrates ............................................................................................................. 4-29 

 4.14.5 Plants ........................................................................................................................ 4-30 

 4.14.6 Diseases .................................................................................................................... 4-33 

 4.15 Habitats ............................................................................................................................. 4-34 

 4.15.1 Coastal Dune/Beach Strand ...................................................................................... 4-34

 4.15.2 Wetlands and Deepwater Habitats ............................................................................ 4-35 

 4.15.3 Coastal Dry Forests .................................................................................................. 4-36 

 4.15.4 Offshore Islet (Molokini) ......................................................................................... 4-37 

 4.16 Ecological and Biological Research ................................................................................. 4-38

Chapter 5. Refuge Facilities and Public Use Programs ................................................................ 5-1 

 5.1 Refuge Infrastructure and Administrative Facilities ....................................................... 5-1 

 5.1.1 Headquarters and Visitor Center .................................................................................. 5-1

 5.1.2 Maintenance Facilities .................................................................................................. 5-2 

 5.1.3 Trails ............................................................................................................................. 5-2 

 5.1.4 Roads and Parking Areas .............................................................................................. 5-3 

 5.1.5 Fences and Gates .......................................................................................................... 5-3 

 5.1.6 Wells, Pumps, Water Distribution Lines, and Water Control Structure ....................... 5-3 

 5.1.7 Visitor and Environmental Education Shelter .............................................................. 5-4 

 5.2 Visitor Services ..................................................................................................................... 5-7 

 5.2.1 Accessibility of Recreation Sites and Programs ........................................................... 5-7 

 5.2.2 Special Use Permits ...................................................................................................... 5-8 

5.3 Wildlife Observation and Photography ............................................................................. 5-8 

 5.3.1 Desired Future Conditions for Wildlife Observation and Photography ....................... 5-8 

5.4 Interpretation ....................................................................................................................... 5-9 

 5.4.1 Desired Future Conditions for the Interpretation Program ......................................... 5-10 

5.5 Environmental Education ................................................................................................. 5-10 

 5.5.1 Desired Future Conditions for the Environmental Education Program ..................... 5-10 

 5.6 Volunteers ........................................................................................................................... 5-11 

 5.6.1 Desired Future Conditions for the Volunteer Program .............................................. 5-11 

 5.7 Partnerships ....................................................................................................................... 5-11 

5.8 Law Enforcement ............................................................................................................... 5-12 

 5.8.1 Desired Future Conditions for Law Enforcement ...................................................... 5-12 

 5.9 Outdoor Recreation Opportunities and Trends on Maui .............................................. 5-13 

 5.9.1 Federal, State, and County Recreational Parks .......................................................... 5-13 

Chapter 6. Cultural Resources, Social, and Economic Environment ......................................... 6-1 

 6.1 Refuge Cultural Resources ................................................................................................. 6-1 

 6.1.1 Mythological and Traditional Accounts ........................................................................ 6-2 

 6.1.2 Pre-Contact History ....................................................................................................... 6-3 

 6.1.3 Euro-American Cultural History ................................................................................... 6-4 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

iv Table of Contents 

 6.1.4 The Mahele, 1848-1851 ................................................................................................. 6-5 

 6.1.5 Post-1850s History ........................................................................................................ 6-5 

 6.1.6 Refuge Archaeological/Cultural Surveys ...................................................................... 6-6 

 6.1.7 Archaeological Resources ............................................................................................. 6-7 

 6.1.8 Paleontological Resources ............................................................................................ 6-7 

 6.2 Social and Economic Setting ............................................................................................... 6-8 

 6.2.1 Population ...................................................................................................................... 6-8 

 6.2.2 Housing ......................................................................................................................... 6-9 

 6.2.3 Education ....................................................................................................................... 6-9 

 6.2.4 Economics ..................................................................................................................... 6-9 

Chapter 7. Environmental Effects Analysis .................................................................................. 7-1 

 7.1 Overview of Effects Analysis .............................................................................................. 7-1 

 7.2 Terminology ......................................................................................................................... 7-1 

 7.3 Summary of Management Action Effects at Keālia Pond NWR ..................................... 7-2 

 7.4 Effects Analysis .................................................................................................................... 7-7 

 7.4.1 Water Level Management Effects to Endangered Waterbirds ..................................... 7-7

 7.4.2 Effects of Management Actions to Migratory Birds .................................................... 7-8

 7.4.3 Effects to Sea Turtles and ‘Īlio-holo-i-ka-uaua ......................................................... 7-10 

 7.4.4 Effects to ‘Ōka‘i ‘aeia ................................................................................................ 7-10 

 7.4.5 Effects of Aquatic Invertebrates ................................................................................. 7-11 

 7.4.6 Control of Pest Plant Species and Native Plant Restoration ...................................... 7-11 

 7.4.7 Predator Control Effects ............................................................................................. 7-12 

 7.4.8 Effects of Management Actions to Restore Coastal Dry Forest Habitat .................... 7-14 

 7.4.9 Effects of Management Actions on Coastal Strand/Dune Habitat ............................. 7-14 

 7.4.10 Effects to Offshore Islet Habitat and Seabirds ............................................................ 7-14 

 7.4.11 Effects of Promoting Research and Scientific Assessments .................................... 7-15 

 7.4.12 Effects to Water, Soils, and Air Quality ................................................................... 7-16 

7.4.13 Effects to Cultural and Historic Resources .............................................................. 7-16 

7.4.14 Effects to Public Use and Access ............................................................................. 7-17 

7.4.15 Economic Impacts ...................................................................................................... 7-18

7.4.16 Environmental Justice................................................................................................. 7-18 

 7.5 Cumulative Effects Assessment ........................................................................................ 7-19 

7.5.1 Cumulative Climate Change Effects on Water Resources.............................................. 7-19

7.5.2 Cumulative Effects to Mā‘alaea Bay .......................................................................... 7-20 

7.5.3 Cumulative Effects to Water Supply Quantity ............................................................... 7-21

7.5.4 Cumulative Effects to Local Traffic Density .................................................................. 7-21

7.5.5 Summary ....................................................................................................................... 7-22

Tables 

Table 2.1 Management Alternatives Summary ................................................................................ 2-17 

Table 3.1 Rates of Water Level Decline for Periods with No Significant Inflow to Pond .................... 3-18 

Table 4.1 Biological Integrity, Diversity, and Environmental Health Characteristics ...................... 4-3 

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

Table 4.3 Conservation targets for the CCP ...................................................................................... 4-6 

Table 4.4 Waterfowl Ecological Attributes, Indicators, and Condition Parameters ........................ 4-16 

Table 4.5 Shorebird Ecological Attributes, Indicators, and Condition Parameters ......................... 4-17 

Table 4.6 Shorebirds of Primary Conservation Importance in the Pacific Region .......................... 4-17 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Table of Contents v 

Table 6.1 Population figures for selected areas ................................................................................. 6-8

Table 6.2 Census Bureau estimated median and per capita income figures, 2009 ............................ 6-10

Table 7.1 CCP Alternatives Summary of Effects for Keālia Pond NWR .......................................... 7-2 

Figures 

Figure 1.1 Map of Main Hawaiian Islands ...................................................................................... 1-15 

Figure 1.2 Map of Refuge Land Status & Boundary ....................................................................... 1-17 

Figure 1.3 Map of Molokini Islet Unit ............................................................................................. 1-19 

Figure 2.1 Map of Alternative A Habitat Management ................................................................... 2-11 

Figure 2.2 Map of Alternative B Habitat Management ................................................................... 2-13 

Figure 2.3 Map of Alternative C Habitat Management ................................................................... 2-15 

Figure 3.1 Average monthly wind speeds at Keālia Pond NWR, 2002-2006.................................... 3-3 

Figure 3.2 Annual cycle of average monthly precipitation (top) and total annual precipitation 

 with 5-year moving average (bottom) at Kīhei, HI, 1950-2008 ................................................. 3-4 

Figure 3.3 Annual cycle of average monthly temperature (top) and mean annual temperature 

 with 5-year moving average (bottom) at Kahului airport, HI, 1955-2008 ............................. 3-6 

Figure 3.4 Water level depths and monthly precipitation at Keālia Pond NWR, 1996-1999 .......... 3-14 

Figure 3.5 Water level depths and monthly precipitation at Keālia Pond NWR, 2000-2003 ......... 3-15 

Figure 3.6 Water level depths and monthly precipitation at Keālia Pond NWR, 2004-2007 .......... 3-16 

Figure 3.7 Predicted and observed salinity concentration as a function of water level elevation ... 3-20 

Figure 3.8 Hourly dissolved oxygen and water level data at Keālia Pond, 2002-2006 ................... 3-21 

Figure 3.9 Hourly pH, turbidity, and water level data at Keālia Pond, 2002-2006 ......................... 3-23 

Figure 3.10 Algal group biovolume as a percent of total biovolume at Keālia Pond, 2002-2005 ... 3-25 

Figure 3.11 Elevation & Contours Map ........................................................................................... 3-27 

Figure 3.12 Pond volume and area as a function of water level elevation, USFWS 2000 .............. 3-29 

Figure 4.1 Peak counts of ae‘o at Keālia Pond, 1995-2010 ............................................................... 4-8 

Figure 4.2 Ae‘o (Hawaiian Stilt) Nesting Areas Map ....................................................................... 4-9

Figure 4.3 ‘Alae ke‘oke‘o (Hawaiian Coot) Nesting Areas Map .................................................... 4-11 

Figure 4.4 Peak counts of ‘alae ke‘oke‘o at Keālia Pond, 1995-2010 ............................................. 4-13 

Figure 4.5 Peak counts of kōlea at Keālia Pond, 1994-2006 ........................................................... 4-18 

Figure 4.6 Peak counts of ‘ūlili at Keālia Pond, 1994-2006 ............................................................ 4-18 

Figure 5.1 Administrative & Public Use Facilities ............................................................................ 5-5 

Appendices 

Appendix A: Keālia Pond National Wildlife Refuge Species Lists .................................................. A-1 

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

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

Appendix D: Wilderness Review for Keālia Pond National Wildlife Refuge .................................. D-1 

Appendix E: Integrated Pest Management Program ......................................................................... E-1 

Appendix F: ESA Section 7 Consultation......................................................................................... F-1 

Appendix G: Fire Management Plan 2004 ....................................................................................... G-1 

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

Appendix I: Literature Cited ............................................................................................................ I-1 

Appendix J: Common Acronyms and Abbreviations ....................................................................... J-1 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

vi Table of Contents 

 

Note to Reviewers: Throughout the CCP document, all attempts have been made 

to use appropriate diacriticals related to the Hawaiian language (i.e., ‘okina and 

kahakō). However, places where diacriticals may not appear occur in the maps 

and literature cited. Due to limitations of the Geospatial Information System 

software used for the maps developed in the plan, some diacriticals may be 

missing where place names or legend text appear. 
Readers’ Guide

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

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

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

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

guide is provided to simplify pronunciation for the reader.

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

1820, western missionaries standardized a written version of the Hawaiian language that features 8

consonants and 5 vowels.

Special Symbols 

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

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

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

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

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

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

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

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

change the meaning of a word is “pau”:

• pau = finished, ended, all done

• pa‘u = soot, smudge, ink powder

• pa‘ū = moist, damp

• pā‘ū = skirt

Refuge Place Names

Keālia (kay-AHH-LEE-ah) meaning: salt encrusted

Mā‘alaea (MAHH ah-la-AY-ah) meaning: red colored earth

Molokini (Mo-lo-KEE-nee) meaning: many ties

Consonants

H - as in English

K - as in English

L - as in English

M - as in English

N - as in English

P - as in English

W - after i and e pronounced v

 - after u and o pronounced like w

 - at the start of a word or after a, 

 pronounced like w or v

(‘) - ‘okina - a glottal stop

Vowels

A - pronounced like the a in far

E - pronounced like the e in bet

I - pronounced like the ee in beet

O - pronounced like the o in sole

U - pronounced like the oo in boot

Readers ’ Guide vii

Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment
Ae‘o (EYE oh)

Hawaiian Stilt Himantopus mexicanus knudseni

SPECIES STATUS:

Federally listed as Endangered

State listed as Endangered

State recognized as Indigenous

‘Alae ke‘oke‘o (ah-lye KAY oh KAY oh)

Hawaiian Coot Fulica alai

SPECIES STATUS:

Federally listed as Endangered

State listed as Endangered

State recognized as Endemic

Nēnē (NAY-NAY)

Hawaiian Goose Branta sandvicensis

SPECIES STATUS:

Federally listed as Endangered

State listed as Endangered

State recognized as Endemic

‘Auku‘u (ow-KOO oo)

Black-crowned Night Heron Nycticorax nycticorax 

hoactli

SPECIES STATUS:

State recognized as Indigenous

Koloa maoli (ko-LOWah MAOW-lee)

Hawaiian Duck Anas wyvilliana

SPECIES STATUS:

Federally listed as Endangered

State listed as Endangered

State recognized as Endemic

Waterbirds

Laura Beauregard

Laura Beauregard

Laura Beauregard

Brenda Zaun

Laura Beauregard

Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment

viii Readers ’ Guide 
‘Akekeke (ah-kay-KAY-kay)

Ruddy Turnstone Arenaria interpres

SPECIES STATUS:

State recognized as Indigenous

U.S. Shorebird Conservation Plan - High Concern

Hunakai (hoo-nah-KYE)

Sanderling Calidris alba

SPECIES STATUS:

State recognized as Indigenous 

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

the receding waves on the shore in search of small sand 

crabs apparently reminded early Hawaiians of the sea 

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

name with a coastal plant. 

Kioea (kee-oh-AY-ah)

Bristle-thighed Curlew Numenius tahitiensis

SPECIES STATUS:

State recognized as Indigenous

IUCN Red List Ranking - Vulnerable

Kōlea (KOHH-lay-ah)

Pacific Golden Plover Pluvialis fulva

SPECIES STATUS:

State recognized as Indigenous 

U.S. Shorebird Conservation Plan - High Concern

‘Ūlili (OOO-lee-lee)

Wandering Tattler Heteroscelus incanus

SPECIES STATUS:

State recognized as Indigenous

U.S. Shorebird Conservation Plan - Moderate Concern

Migrant Shorebirds

Laura Beauregard

©Michael Walther

©Michael Walther

©Michael Walther

Keālia Pond National Wildlife Refuge 

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Readers ’ Guide ix

©Michael Walther
‘A‘o (AH-oh)

Newell’s Shearwater Puffinus auricularis newelli

SPECIES STATUS:

Federally listed as Threatened

State listed as Threatened

State recognized as Indigenous 

Mōlī (MOE-lee)

Laysan Albatross Phoebastria immutabilis

SPECIES STATUS:

State recognized as Indigenous

North American Waterbird Conservation Plan - High 

concern

‘Ua‘u kani (OO-ah oo KAH-nee)

Wedge-tailed Shearwater Puffinus pacificus

SPECIES STATUS:

State recognized as Indigenous

‘Iwa (EE-vah)

Great Frigatebird Fregata minor palmerstoni

SPECIES STATUS:

State recognized as Indigenous

‘Ou (OH-oo)

Bulwer’s Petrel Bulweria bulwerii 

SPECIES STATUS:

State recognized as Indigenous

Seabirds

Beth Flint

Lindsay Young

USFWS

USFWS

NPS

x Readers ’ Guide

Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment
‘Ōka‘i ‘aiea (OHH-kah ee eye-AY-ah)

Blackburn’s Sphinx Moth Manduca blackburni

SPECIES STATUS:

Federally listed as Endangered

State listed as Endangered

State recognized as Endemic

Honu ‘ea (HO-noo AY-ah)

Hawksbill Turtle Eretmochelys imbricata

SPECIES STATUS:

Federally listed as Endangered

State listed as Endangered

Honu (HO-noo )

Hawaiian Green Turtle Chelonia mydas

SPECIES STATUS:

Federally listed as Threatened

State recognized as Indigenous

IUCN Red List Ranking - Endangered 

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

OO-ah OO-ah)

Hawaiian Monk Seal Monachus schauinslandi

SPECIES STATUS:

Federally listed as Endangered

Pueo (poo-AY-oh)

Hawaiian Short-eared Owl Asio flammeus 

sandwichensis

SPECIES STATUS:

State recognized as Endangered on O‘ahu

State recognized as Endemic

Native Animals

Laura Beauregard

NOAA

Ellen VanGelder 

©Tom Dove

George Balazs

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‘Ākulikuli (AAH-koo-lee-KOO-lee)

Sea Purslane Sesuvium portulacastrum

SPECIES STATUS:

State recognized as Indigenous

‘Āki‘aki (AH-kee AH-kee)

Beach Dropseed Sporobolus virginicus

SPECIES STATUS:

State recognized as Endemic

Pōhuehue (POHH-hoo-ay-HOO-ay)

Beach Morning Glory Ipomoea pescaprae

SPECIES STATUS:

State recognized as Indigenous

Native Plants - Herbs

‘Ilima (ee-LEE-mah)

Yellow Ilima Sida Fallax

SPECIES STATUS:

State recognized as Indigenous

‘Ihi (EE-hee)

Ihi Portulaca molokiniensis

SPECIES STATUS:

Federally listed as Endangered

Laura Beauregard

Laura Beauregard

Laura Beauregard

Forest & Kim Starr

Laura Beauregard

xii Readers ’ Guide

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Hala (HAH-lah)

Beach Vitex Pandanus tectorius

SPECIES STATUS:

State recognized as Indigenous

‘Ōhelo kai (OHH-heh-loh KYE)

Hawai‘i Desert-thorn Lycium sandwicense

SPECIES STATUS:

State recognized as Indigenous

Naio (NYE-oh)

False Sandalwood Myoporum sandwicense

SPECIES STATUS:

State recognized as Indigenous

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

Beach Naupaka Scaevola taccada

SPECIES STATUS:

State recognized as Indigenous

Pōhinahina (POHH-hee-nah HEE-nah)

Beach Vitex Vitex rotundifolia

SPECIES STATUS:

State recognized as Indigenous

Native Plants - Shrubs & Trees

Laura Beauregard

Forest & Kim Starr

Laura Beauregard

Forest & Kim Starr

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Laura Beauregard
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Keālia Pond National Wildlife Refuge 

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Chapter 1. Introduction and Background 1-1 

Chapter 1. Introduction 

Keālia Pond National Wildlife Refuge (NWR or Refuge) was established in 1992 to preserve, 

restore, and manage essential habitat for two endangered Hawaiian waterbirds: the ae‘o (Hawaiian 

stilt) and ‘alae ke‘oke‘o (Hawaiian coot). The 704-acre Refuge is situated along the south-central 

shore of Maui in the isthmus separating the West Maui Mountains from the East Maui volcano, 

Haleakalā. Refuge habitats include open water (200 acres), vegetated flats (450 acres), and upland 

(54 acres). Keālia Pond is a significant foraging and nesting area for Hawai‘i’s endangered wetland 

birds, and is host to hundreds of migratory shorebirds and waterfowl during winter months. In 

addition, the Refuge provides coastal beach strand habitat for native plant species, endangered ‘īlioholo-i-ka-uaua (Hawaiian monk seal), threatened honu (Hawaiian green turtle), and endangered honu 

‘ea (hawksbill turtle). 

The proposed 23-acre Molokini Unit (see page 1-7) of the Refuge encompasses a crescent-shaped 

islet located between the Islands of Maui and Kaho‘olawe. It has a diameter of about 0.4 miles and 

hosts a colony of ‘ua‘u kani (wedge-tailed shearwaters) that nest from March-December. Other 

inhabitants include a smaller nesting population of ‘ou (Bulwer’s petrel), ‘iwa (great frigate), noio 

(black noddy), and noio kōhā (brown noddy) that use the island for roosting. The ‘ihi plant 

(Portulaca molokiniensis) is a rare Hawaiian endemic known from only two locations, one on 

Molokini and one on Kaho‘olawe. 

The Molokini Unit, Keālia Pond NWR, and Kakahai‘a NWR (located on the southeastern coast of 

Moloka‘i) make up the Maui National Wildlife Refuge Complex (Complex). This Comprehensive 

Conservation Plan (CCP) will focus on the Keālia Pond NWR and the Molokini Unit. 

 

Ae‘o duo © Tony Temple
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1-2 Chapter 1. Introduction and Background 

1.1 Proposed Action 

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

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

the Refuge. This document is the Refuge’s Draft Comprehensive Conservation Plan and 

Environmental Assessment (CCP/EA) and includes all lands within the approved boundary. A CCP 

sets forth management guidance for a refuge for a period of 15 years, as required by the National 

Wildlife Refuge System Administration Act of 1966 (16 U.S.C. 668dd et seq.) as amended by the 

National Wildlife Refuge System Improvement Act of 1997 (Pub. Law 105-57) (Administration 

Act). The Administration Act requires CCPs to identify and describe: 

 The purpose(s) of the refuge; 

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

values found on the refuge; 

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

correct or mitigate those problems; 

 Areas suitable for administrative sites or visitor facilities; and 

 Opportunities for fish and wildlife-dependent recreation. 

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

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

management direction to achieve refuge purposes; help fulfill the National Wildlife Refuge System 

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

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

We have developed and examined alternatives for managing Keālia Pond NWR through the CCP 

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

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

Management options are consolidated into three alternatives with alternative C identified as the 

preferred alternative. This alternative represents the best balanced approach for achieving the 

Refuge’s purposes, vision, and goals; contributing to the Refuge System mission; and addressing the 

relevant issues and mandates consistent with sound principles of fish and wildlife management. 

However, the selected alternative may be modified between the draft and final document depending 

upon comments received from the public or other agencies and organizations. The Regional Director 

for the Service’s Pacific Region will be the final decision maker regarding the alternative that will be 

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

of alternatives, see Chapter 2. 

1.2 Purpose and Need for the CCP 

The purpose of the proposed CCP is to provide the Service, the Refuge System, partners, and citizens 

with a management plan for improving fish and wildlife habitat conditions and Refuge infrastructure, 

for wildlife and public use on Keālia Pond NWR over the next 15 years. An approved CCP will 

ensure that the Service manages to achieve the Refuge purposes, vision, goals, and objectives to help 

fulfill the mission of the Refuge System. 

 
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Chapter 1. Introduction and Background 1-3 

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

habitat conditions on the Refuge‟s wetland habitats, which are degraded by invasive plants and 

animals. The plan also recognizes and identifies threats to the endangered ae„o and „alae ke„oke„o, 

including predation by non-native mammals, limited water supply, and human disturbance. There is 

also a need to address public concern about the seasonal conditions within the wetland and the 

associated biological processes. 

There is also a need to analyze Refuge public use programs for Refuge System wildlife-dependent 

priority public uses and to determine what improvements or alterations should be made in the pursuit 

of higher quality programs (See Chapter 5 for more on priority public uses). This will include a 

determination on whether and how the Refuge should consider other non-wildlife-dependent uses, 

including commercial guiding activities. Finally, there is a need to describe the steps that should be 

taken to better protect the habitats and wildlife through strategies to accomplish our goals. 

1.3 Content and Scope of the Plan

This draft CCP/EA provides guidance for management of Refuge habitats and wildlife and 

administration of public uses on Refuge lands and waters. This CCP/EA is intended to comply with 

both the Administration Act and the National Environmental Policy Act (NEPA), as amended (42 

U.S.C. 4321-4347). Information included in the CCP includes: 

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

local ecosystem (Chapter 1); 

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

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

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

A description of conservation targets, condition, and trends on the Refuge (Chapter 4); 

An account of the Refuge‟s facilities and visitor programs (Chapter 5); 

An overview of cultural resources, social, and economic environment (Chapter 6);

An analysis of the environmental effects associated with implementing the management 

actions prescribed under the alternatives described in Chapter 2 (Chapter 7);

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

(Appendix A); 

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

with the Refuge‟s purpose (Appendix B); 

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

Wilderness Review (Appendix D); 

Integrated Pest Management (Appendix E); 

Endangered Species Act Section 7 S-Methoprene Evaluation (Appendix F); 

Fire Management Plan (Appendix G); 

Statement of Compliance (Appendix H); 

Literature Cited (Appendix I); and 

Common Acronyms and Abbreviations (Appendix J). 
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1-4 Chapter 1. Introduction and Background 

1.4 Planning and Management Guidance 

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

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

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

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

designated purpose of the Refuge as described in establishing legislation, Executive orders, or other 

documents establishing, authorizing, or expanding a refuge. 

Key concepts and guidance of the Refuge System derive from the Administration Act, the Refuge 

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

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

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

the CFR. These regulations govern general administration of units of the Refuge System. 

1.4.1 U.S. Fish and Wildlife Service Mission 

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

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

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

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

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

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

programs, and helps other countries develop wildlife conservation programs. 

1.4.2 National Wildlife Refuge System 

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

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

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

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

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

environmental education (EE) and interpretive activities on national wildlife refuges. 

1.4.3 National Wildlife Refuge System Mission and Goals 

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

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

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

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

policy (601 FW1), follow: 

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

endangered or threatened with becoming endangered; 
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Chapter 1. Introduction and Background 1-5 

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

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

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

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

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

underrepresented in existing protection efforts; 

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

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

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

wildlife, and plants and their habitats. 

1.4.4 National Wildlife Refuge System Administration Act of 1966 

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

greatest influence and included a unifying mission for all national wildlife refuges, a new process for 

determining compatible uses on refuges, and a requirement that each refuge will be managed under a 

CCP developed in an open public process. The Administration Act states that the Secretary shall 

provide for the conservation of fish, wildlife, plants, and their habitats within the Refuge System, and 

ensure that the biological integrity, diversity, and environmental health of the Refuge System are 

maintained. House Report 105–106 accompanying the Improvement Act states ‘‘...the fundamental 

mission of our System is wildlife conservation: wildlife and wildlife conservation must come first.’’ 

Biological integrity, diversity, and environmental health are critical components of wildlife 

conservation. As later made clear in the Biological Integrity, Diversity, and Environmental Health 

policy (601 FW 3), “the highest measure of biological integrity, diversity, and environmental health 

is viewed as those intact and self-sustaining habitats and wildlife populations that existed during 

historic conditions.” 

Each refuge must be managed to fulfill the Refuge System mission as well as the specific purpose(s) 

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

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

uses are granted special consideration in the planning, management, establishment, and expansion of 

units of the Refuge System: hunting, fishing, wildlife observation and photography, and EE and 

interpretation. When determined compatible on a refuge-specific basis, these six uses assume priority 

status among all public uses of the refuge in question. The overarching goal is to enhance wildlifedependent recreation opportunities and access to high-quality visitor experiences on refuges, while 

managing refuges to conserve fish, wildlife, plants, and their habitats. The Service is directed to 

make extra efforts to facilitate wildlife-dependent visitor opportunities. 

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

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

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

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

goals and objectives described in an approved refuge management plan. A compatible use is defined 

as a use that, in the sound professional judgment of the refuge manager, will not materially interfere 

with or detract from the fulfillment of the mission of the Refuge System or the purpose(s) of the 

refuge. Current Appropriate Use Findings and Compatibility Determinations for existing and 

proposed uses for Keālia Pond NWR are in Appendix B. 
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1-6 Chapter 1. Introduction and Background 

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

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

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

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

to securing public input throughout the process. 

1.5 Refuge Establishment and Purpose 

1.5.1 Legal Significance of the Refuge Purpose 

The purpose for which a refuge was established or acquired is of key importance in refuge planning. 

Purposes must form the foundation for planning and management decisions. The purpose(s) of a 

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

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

expanding a refuge, refuge unit, or refuge subunit. 

Unless the establishing law, order, or other document indicates otherwise, purposes dealing with the 

conservation, management, and restoration of fish, wildlife, and plants, and the habitats on which 

they depend take precedence over other purposes in the management and administration of any unit. 

Where a refuge has multiple purposes related to fish, wildlife, and plant conservation, the more 

specific purpose will take precedence in instances of conflict. When an additional unit is acquired 

under an authority different from the authority used to establish the original unit, the addition takes 

on the purpose(s) of the original unit, but the original unit does not take on the purpose(s) of the 

newer addition. 

By law, refuges are to be managed so as to achieve their purposes. When a conflict exists between 

the Refuge System mission and the purpose of an individual refuge, the refuge purpose supersedes 

the Refuge System mission.

1.5.2 Refuge Establishment 

Keālia Pond NWR was established in 1992 under the authority of the Endangered Species Act of 

1973 (ESA). The Refuge was funded through the Land and Water Conservation Act of 1965. Prior 

to establishment as a national wildlife refuge, the Service and State of Hawai‘i periodically 

conducted avian surveys at Keālia Pond and consistently observed high numbers of ae‘o and ‘alae 

ke‘oke‘o, both of which were Federally listed as endangered species in 1970. Such was the impetus 

for protecting this large wetland from future development. 

The Service is in the process of establishing Molokini islet as an “overlay refuge” attached to the 

Keālia Pond NWR. The designation will protect Molokini’s large colony of nesting seabirds and help 

with restoring native plant species. The islet, the crescent-shaped rim of a volcanic crater, remains 

under U.S. Coast Guard (USCG) ownership, but its transfer to the Service is currently under 

negotiation. A land-ownership transfer would create a permanent refuge in lieu of an overlay refuge. 
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Chapter 1. Introduction and Background 1-7 

The (overlay) refuge would include only the land 

itself, and the State would continue to manage the 

surrounding Molokini shoals as a State Marine Life 

Conservation District. 

1.5.3 Refuge Purpose

Refuge purposes are also the driving force in the 

development of the refuge vision statements, goals, 

objectives, and strategies in the CCP and are critical 

to determining the appropriateness and compatibility 

of all existing and proposed refuge uses. Keālia 

Pond NWR was established with the purpose “... to 

conserve (A) fish or wildlife which are listed as 

endangered species or threatened species, or (B) 

plants ...” (16 U.S.C. 1534, ESA). 

1.6 Refuge Goals 

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

focus management priorities, resolve issues, and link to refuge purpose(s), Service policy, and the 

Refuge System mission. A CCP describes management actions that help bring a refuge closer to its 

vision. A vision broadly reflects refuge purposes, Refuge System mission and goals, other statutory 

requirements, and larger-scale plans as appropriate. Wildlife, habitat, and visitor services 

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

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

identify specific tools and actions to accomplish objectives. The Refuge vision statement is found on 

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

priority in this CCP. 

 

Molokini USFWS
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1-8 Chapter 1. Introduction and Background 

Nā Pahuhopu Pu‘uhonua Holoholona 

1. Kīa‘i a mālama i nā ‘āina pālialia a me ālialia wai maoli nohokau a me nā pālialia noho manawa 

no ka mālama ‘ana i ka mō‘aukala ola pono o nā manukai/wai Hawai‘i ‘ane make loa. 

2. Ho‘onui aku i nā kaianoho o nā holoholona ‘ane make loa no ka ho‘omāhuahua hou ‘ana aku iā

lākou iho. 

3. Kīa‘i, ho‘ōla hou, a mālama i nā kaianoho lihikai no ka pono no ka ho‘opunana ‘ana o nā honu 

kai, manu kai, a me ka kūkahi o kēia mau kaiaola pio/pau wale. 

4. Kīa‘i a mālama i ka ‘āina li‘ili‘i ma waho mai o Moloka‘i i kapa ‘ia o Molokini i kaianoho no nā

manu kai ho‘opūnana. 

5. ‘Ohi‘ohi i nā waiwai ‘epekema (nānā, noi‘i, a me ka ho‘ā‘o ‘ana) no ke kāko‘o ‘ana i nā

makemake o ka mālama ‘ia ‘ana ma ka pahuhopu helu 1 a helu 4 no ka pu‘uhonua holoholona. 

6. Ho‘omākaukau i kumu waiwai nui no nā kaianoho mākaukau no na holoholona ‘āhiu, a e kokua 

ho‘i i ka lehulehu ma ka ho‘onā‘auao a a‘o mai iā lākou e pili ana i nā i‘a, nā holoholona hihiu, a 

me nā waiwai nohona ‘ōiwi o kēia wahi nei i kapa ‘ia o Keālia Pond NWR. 

7. Ho‘omākaukau ho‘i i polokalamu waiwai loa no ke a‘o ‘ana i nā haumāna e pili ana i nā

kumuhana kūpono a me ka hana lima pu ma nā kaianoho holoholona hihiu. 

Refuge Goals 

1. Protect and maintain seasonal and semi-permanent wetland habitats to meet the life history needs 

of endangered Hawaiian waterbirds. 

2. Expand protected species’ habitat to promote their recovery. 

3. Protect, restore, and manage coastal habitat for the benefit of nesting sea turtles, seabirds, and the 

integrity of the fragile ecosystem. 

4. Protect and maintain offshore Molokini islet habitat for seabird nesting. 

5. Gather scientific information (survey, research, and assessments) in support of adaptive 

management decisions on the Refuge under Goals 1-4. 

6. Through quality wildlife-dependent recreation and learning opportunities, visitors understand and 

appreciate the unique wildlife and habitats of Keālia Pond NWR.

7. Provide students and teachers high-quality hands-on environmental education programs that 

foster a connection with nature and the Refuge.
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Chapter 1. Introduction and Background 1-9 

1.7 Relationship to Previous and Future Refuge Plans

Planning has been a part of refuge operations since their beginning. Although not all were conducted 

in a comprehensive fashion, or with public participation considered adequate today, a considerable 

number of plans were completed over the years to guide managers. Additional smaller “step-down” 

plans and management agreements (plans addressing one program or resource) will be developed for 

the Refuge in conjunction with the CCP. Current management plans include: 

 Fire Management Plan - 2004 

 Integrated Pest Management Plan - 2008 

 Station Safety Plan - 2010 

 Highly Pathogenic Avian Influenza Disease Contingency Plan - 2009 

 Avian Botulism Disease Contingency Plan - 2008 

 Emergency Preparedness Response Plan - 2010 

 Continuity of Operations Plan - 2010 

 Station Hazardous Communications Plan - 2010 

In progress Memorandum of Agreement (MOA)s include: 

 U.S. Coast Guard - Molokini Islet Access 

 Hawai‘i Department of Land and Natural Resources (DLNR) - Molokini Islet Management

1.7.1 Future Planning 

The CCP will be revised every 15 years or earlier if monitoring and evaluation determine that 

changes are needed to achieve the Refuge purposes, vision, goals, or objectives. The CCP provides 

guidance in the form of goals, objectives, and strategies for Refuge programs areas but may lack 

some of the specifics needed for implementation. Step-down management plans will therefore be 

developed for individual program areas, as needed, following completion of the CCP. Step-down 

plans require appropriate NEPA compliance.

1.8 Relationship to Ecosystem Planning Efforts 

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

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

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

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

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

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

Beach Management Plan for Maui. The Beach Management Plan is specific to Maui County and is 

a guiding policy document to promote beach preservation and sustainable development of the coastal 

zone. The Plan includes issues on coastal erosion and beach loss, and recommendations for more 

efficient management of shoreline areas for resource conservation and erosion mitigation. Keālia 

Pond NWR’s southern boundary does not include beachfront habitat at this time; however, protecting 

the integrity of the shoreline habitat also protects the Refuge’s coastal flats habitat for endangered 

waterbirds. The Refuge’s coastal habitat goal and strategies references this plan not only for the 
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1-10 Chapter 1. Introduction and Background 

habitat but also to establish collaborative efforts with Federal, State, and County agencies, 

organizations, and landowners who have similar goals. 

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

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

develop its own comprehensive wildlife conservation strategy. Hawai‘i’s Comprehensive Wildlife 

Conservation Strategy thoroughly reviews the status of the full range of the State’s native terrestrial 

and aquatic species, over 10,000 of which are found nowhere else on Earth. Hawai‘i’s Species of 

Greatest Conservation Need include all native terrestrial animals, all endemic aquatic animals, 

additional indigenous aquatic animals identified as in need of conservation attention, a range of 

native plants identified as in need of conservation attention, and all identified endemic algae. This list 

includes: terrestrial mammal (1), birds (77), terrestrial invertebrates (~5,000), freshwater fishes (5), 

freshwater invertebrates (12), anchialine pond-associated fauna (20), marine mammals (26), marine 

reptiles (6), marine fishes (154), marine invertebrates (197), and flora (over 600). Details on all the 

listed wildlife taxa are provided in fact sheets that contain information for taxa, closely related 

groups of species, and species facing similar threats. 

Hawai‘i Nongame Management Program (Draft), 2000. The goal of the Hawai‘i Nongame 

Management Program is to manage, preserve, and protect the native avifauna and their habitats for 

their intrinsic, recreational, scientific, and educational values and to provide opportunities for the 

residents and visitors to Hawai‘i to use and enjoy these resources. A major focus of the program is 

on management and recovery of endangered species, including projects to monitor, manage habitat, 

and recover populations and control of predators affecting endangered species. Other nongame 

projects include increased surveillance of non-native pests, construction of facilities and 

infrastructure to promote management or recreational opportunities to enjoy nongame resources, and 

maintenance of those facilities. 

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

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

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

waterbirds focuses on the following objectives: 

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

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

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

range; 

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

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

conditions and control of invasive nonnative plants; 

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

avian diseases, and contaminants; and 

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

mallards. 

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

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

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

islands due to increasing development pressures and already limited acreage. Monitoring and 
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Chapter 1. Introduction and Background 1-11 

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

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

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

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

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

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

Commonwealth, and State governments will need to work together with military agencies, nongovernmental organizations, and the scientific community. On a larger scale, coordination at the 

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

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

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

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

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

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

Hawai‘i, honu populations appear to have a somewhat less dire status, probably due to effective 

protection at the primary nesting areas of the Northwestern Hawaiian Islands (NWHI) and better 

enforcement of regulations prohibiting take of the species. However, an increase in the incidence of 

the tumorous disease, fibropapillomatosis, in the Hawaiian honu threatens to eliminate improvements 

in the status of the stock. Another serious threat to honu populations throughout the Pacific is 

associated with increasing human populations and development. In particular, human development is 

having an increasingly serious impact on nesting beaches. 

Pacific Coast Joint Venture, Hawai‘i, 2006. This strategic plan for waterbirds and wetlands 

identifies management strategies for a diversity of resident and migratory species with varying life 

history requirements across multiple sites to fulfill archipelago-wide conservation goals to “protect, 

restore, increase, and enhance all types of wetlands, riparian habitats, and associated uplands 

throughout the Pacific Coast region to benefit birds, fish and other wildlife” (Henry 2006). To 

accomplish this goal, six strategies are employed: protection, restoration, enhancement and 

management advocacy, outreach, and research. Habitat goals for the Pacific Coast Joint Venture

(PCJV) strategic conservation plan in Hawai‘i represent long ranging concepts that provide direction 

for conservation objectives and actions. They are based on the strategies identified by the PCJV and 

support goals identified by other avian conservation plans for Hawai‘i. 

Draft Recovery Plan for the Blackburn’s Sphinx Moth (Manduca blackburni), 2003. The ‘ōka‘i 

‘aiea (Blackburn’s sphinx moth) is federally listed as endangered. This taxon is currently known to 

occur on three of the seven major Hawaiian Islands. No known ‘ōka‘i ‘aiea populations are entirely 

protected from the numerous factors threatening the species’ recovery, and the moth is endangered 

throughout its range. Needed conservation and recovery activities include protection, management, 

and restoration of habitat; out-planting of native Nothocestrum spp. (‘aiea) host plants; and a captive 

breeding or translocation program. 

Recovery Plan for U.S. Pacific Populations of the Hawksbill Turtle, 1998. The honu ‘ea (hawksbill 

turtle) is listed as endangered throughout its range. In the Pacific, this species is rapidly approaching 

extinction due to a number of factors, but the intentional harvest of the species for meat, eggs, and 

the tortoiseshell and stuffed curio trade is of greatest impact. Increasing human populations and the 

concurrent destruction of the habitat are also of major concern for honu ‘ea. The status of this species 
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is clearly of highest concern for the Pacific and it is recommended that immediate actions be taken to 

prevent its extinction. 

1.9 Planning and Issue Identification 

1.9.1 Issues to be Addressed in the Draft CCP 

The following issues are being addressed in the planning process: 

Wildlife and Habitat Resources: Endangered waterbirds are the primary management focus, but 

management also considers and includes endangered ‘ōka‘i ‘aiea and honu ‘ea, threatened honu, 

migratory shorebirds, waterfowl, seabirds, and native plant species. The Service is concerned with 

threats posed to native habitats and wildlife at Keālia Pond from invasive plants like California 

bulrush and pickleweed, and pest animals such as rats, mongooses, and cats. 

Invasive aquatic insects and fish: Environmental conditions within the pond often times lead to 

increased emergence of native and non-native midges (non-biting mosquito-like insects) and fish dieoffs. The occurrence of these events is reported as a nuisance by local communities. The CCP will 

identify strategies to ameliorate midges and tilapia while adhering to the purpose of the Refuge. 

Facilities and Facilities Maintenance: The maintenance of current facilities includes vehicles and 

farm tractors; metal shipping containers that house shop maintenance and office storage; boundary 

fencing; ditches, dikes, and impoundments; water control structures; and wells and pumps. Due to 

the environmental conditions (e.g., constant wind containing salt spray and precipitation, warm 

temperatures, high humidity) associated with this coastal marine environment, degradation of 

equipment and facilities is accelerated and often exceeds normally acceptable mainland standards for 

maintenance costs and schedules. 

Visitor Services Activities: Keālia Pond NWR provides opportunities for EE and interpretation, 

wildlife observation, and wildlife photography during much of the year. The Service must balance 

visitor use and wildlife protection and will ensure public use is managed to keep visitors in areas 

where visitor facilities can be constructed to prevent disturbance to wildlife and habitat. 

Compatibility Determinations (CD) for EE, interpretation, wildlife observation, and photography 

were approved in 2004, but will be re-evaluated during the CCP planning process. 

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

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

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

Adaptive Management: More data on impacts of pest species; hydrology; seabird nesting on 

Molokini; and inter-island dispersal patterns of endangered waterbirds is needed. This lack of data 

hinders the Service’s ability to respond effectively to resource changes and to use adaptive 

management to evaluate the effectiveness of its management practices. The CCP will examine these 

inventory, monitoring and research needs and the public’s role in determining and meeting these 

needs. 

 
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1.9.2 Issues Outside the Scope of the Draft CCP 

Off-shore Fishing Activities: Fishing activities at Keālia Beach are not within the scope of this 

CCP as much of the coastal property is privately owned by Alexander and Baldwin Properties, Inc. 

(A&B, Inc.) and ocean-related opportunities and regulations fall within the jurisdiction of the State 

DLNR Division of Aquatic Resources (DAR) and Division of Conservation and Resource 

Enforcement (DOCARE). 

 
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Figure 1.1 – Main Hawaiian Islands
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To preserve the quality of the map, this side was left blank intentionally. 

 
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 Figure 1.2 – Refuge Land Status & Boundary 
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To preserve the quality of the map, this side was left blank intentionally. 
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Figure 1.3 – Molokini Islet Unit 
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To preserve the quality of the map, this side was left blank intentionally. 
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Chapter 2. Alternatives, Goals, Objectives, and Strategies 2-1

Chapter 2. Alternatives, Goals, Objectives, and Strategies 

2.1 Considerations in Alternative Design 

During development of the Draft CCP/EA alternatives presented in this chapter, the Service reviewed 

and considered a variety of resources, social, economic, and organizational aspects important for 

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

fundamental in designing alternatives. House Report 105-106 accompanying the National Wildlife 

Refuge System Improvement Act of 1997 (Pub. Law 105-57) states “...the fundamental mission of 

our System is wildlife conservation: wildlife and wildlife conservation must come first.”

The Service planning team reviewed and utilized available scientific information (reports and 

studies) to better understand ecosystem trends and the latest scientific recommendations for species 

and habitats. The team also met with staff from local, State and Federal agencies, and elected 

officials to ascertain priorities and problems as perceived by others. Refuge staff also met with 

Refuge users, non-profit groups, and community organizations to ensure their comments and ideas 

were considered during CCP development.

2.2 Alternative Components Not Considered for Detailed Analysis 

This CCP for Keālia Pond NWR will not cover issues related to traffic and highway construction. 

Recommendations made at the scoping meeting to construct a bypass road behind the Refuge and 

close N. Kīhei Rd. to pedestrian access and controlling the speed of traffic on this same road are 

beyond the Service’s jurisdiction. Construction of a bypass would require collaboration between 

Hawai‘i Department of Transportation (HDOT), County of Maui, and Hawaiian Commercial and 

Sugar Company (HC&S). The Service would discuss the feasibility of the project if the proposal is 

initiated by the State or County agencies.

2.3 Elements Common to All Alternatives 

All the alternatives contain some common features. To reduce the length and redundancy of the 

individual alternative descriptions, common elements are presented below. 

2.3.1 Implementation Subject to Funding Availability 

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

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

continue, also dependent on funding. It is the intent of the Refuge that annual priorities would follow 

the final CCP guidelines, although funding initiatives, unforeseen management issues, and budgets 

may vary from year to year. The CCP will be reviewed every year and updated as necessary 

throughout its life. 

 
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2.3.2 Interagency Coordination and Collaboration

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

State, and local agencies toward mutual goals. Under all alternatives, the Service will continue to 

maintain regular discussions and partnership with the DLNR. Topics for discussion continue to be 

the endangered waterbirds at Keālia Pond NWR and surrounding private and public lands, and 

wildlife monitoring. A cooperative agreement with DLNR will be established for Molokini to define 

a collaborative effort for continuing the seabird monitoring program, plant native species, and 

provide transportation to the islet. 

2.3.3 Threatened and Endangered Species Protection and Recovery

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

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

national wildlife refuges. The protection of federally listed species is mandated through Section 7 of 

the ESA, called “Interagency Cooperation,” is the mechanism by which Federal agencies ensure the 

actions they take, including those they fund or authorize, do not jeopardize the existence of any listed 

species. To ensure adequate protection, the Refuge is required to review all activities, programs, and 

projects occurring on lands and waters of the Refuge to determine if they may affect listed species. If 

the determination is that an action may affect an endangered species, then the Refuge conducts a 

formal review, known as a consultation, to identify those effects and means to mitigate those effects. 

Consultation is being conducted concurrent with development of the CCP and the resulting 

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

2.3.4 Historic and Cultural Resource Protection

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

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

established by the Department of the Interior (DOI) and the Service. Refuge management actions will 

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

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

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

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

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

cultural items — human remains, funerary objects, sacred objects, or objects of cultural patrimony —

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

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

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

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

Affairs and Hui Malama i na Kupuna ‘o Hawai‘i Nei. The DOI has interpreted this definition to also 

include the Hawaiian island burial councils and various ‘ohana (extended families). 

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

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

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

alternatives being considered. The RHPO will analyze these undertakings for potential to affect 
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historic properties and enter into consultation with the State Historic Preservation Officer (SHPO) 

and other parties as appropriate. The Refuge will also ask the public and local government officials to 

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

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

2.3.5 Fire Management

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

resource protection, public safety, and habitat management on national wildlife refuges. The Fire 

Management Plan (Appendix G) provides detailed guidance for the suppression and use of prescribed 

fire. That plan’s actions and effects are incorporated through reference in this CCP/EA. The plan 

outlines wildfire response and prescribed fire objectives, strategies, responsibilities, equipment and 

staffing; burn units; implementation; monitoring; and evaluation. 

2.3.6 Participation in Planning and Review of Regional Development 

 Activities

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

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

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

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

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

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

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

land acquisition that will benefit Refuge purposes. 

2.3.7 Adaptive Management 

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

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

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

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

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

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

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

management actions and other events become better understood.” 

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

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

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

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

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

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

evaluation of the CCP. 

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

year revision of the CCP. The revision will be initiated by the Service and will involve many of the 
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same steps as this Draft CCP/EA including comprehensive review of management plans and 

research; working closely with partners; and engaging the public. 

2.3.8 Integrated Pest Management 

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

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

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

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

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

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

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

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

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

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

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

Insecticide, Fungicide, and Rodenticide Act and as provided in regulations, orders, or permits issued 

by EPA, that it is registered for use in the State of Hawai‘i, may be applied on lands and waters under 

Refuge jurisdiction. 

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

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

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

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

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

reproducing; outcompeting them for food, nutrients, light, nest sites, or other vital resources; or 

hybridizing with them so frequently that within a few generations, few if any truly native individuals 

remain. Environmental harm also can be the result of an indirect effect of pest species. For example, 

decreased waterfowl use may result from pest plant infestations reducing the availability and/or 

abundance of native wetland plants that provide forage during the winter. 

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

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

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

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

minor, temporary, and localized effects to species and environmental quality based upon nonexceedance of threshold values in chemical profiles. However, pesticides may be used on Refuge 

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

in order to protect human health and safety (e.g., mosquito-borne disease). For more information on 

strategies related to control of pests, see Appendix E. 

 
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2.3.9 National Environmental Policy Act Compliance 

Since this EA and CCP are programmatic in many issue areas, it may not contain the necessary detail 

on every future action outlined to adequately present and evaluate all physical, biological and 

socioeconomic impacts. For example, although the EA and CCP alternatives may show the proposed 

number and location of features such as fences, overlooks, and roads; the exact location, size, design, 

and other criteria related to these features would be determined at a later date depending on funding 

and implementation schedules. Another example is the various sub or “step-down” plans required 

for various management actions such as visitor services and transportation. Thus, before certain 

objectives or actions are implemented, a decision will be made in coordination with the Regional 

NEPA Coordinator on whether this EA was adequate for each specific construction, planning, or 

other action, or whether separate step-down NEPA compliance (categorical exclusions, 

environmental assessments, or an environmental impact statement) is needed. 

2.3.10 Law Enforcement

Officers’ Responsibilities 

Fish and wildlife law enforcement issues on lands and waters of the Keālia Pond NWR are under the 

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

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

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

highly mobile and is frequently deployed temporarily to various areas throughout the State of 

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

been identified in the Implementation Plan (Appendix C). 

Officers’ Authority

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

including but not limited to: 

 Administration Act; 

 The Lacey Act; 

 Archaeological Resources Protection Act; 

 Endangered Species Act; 

 Migratory Bird Treaty Act; and 

 Marine Mammal Protection Act. 

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

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

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

Service Officers work joint patrols and coordinate with DOCARE, Maui Police Department, and the 

Sheriff Division of the State Department of Public Safety. 

   
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2.4 Alternatives Descriptions

Each alternative describes a combination of habitat and visitor management prescriptions designed to 

achieve the Refuge purpose, goals, and vision. These alternatives provide different ways to address 

and respond to major public issues, management concerns, and opportunities identified during the 

planning process. All of the major issues, activities, and management concerns were evaluated and 

addressed for each alternative and are shown in the corresponding maps found in this chapter. A 

summary of the key differences between the alternatives is presented in Table 2.1 on page 2-17. 

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

the latitude managers have within the framework of Refuge System laws and policy. The alternatives 

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

refuges, and a host of ongoing conservation initiatives affecting the Hawaiian Islands. The 

alternatives were developed to address a suite of issues, and indeed are structured to track the issues, 

challenges, and opportunities presented in Chapter 1. 

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

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

importantly, these alternatives are designed to help Keālia Pond NWR contribute to the mission of 

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

Refuge vision, goals, and objectives. Step-down plans for Visitor Services, Transportation, and 

Habitat Restoration would be developed under Alternatives B and C. 

2.4.1 Alternative A: Continue Current Management Activities

This alternative assumes no change in current management programs and is considered the base from 

which to compare the other alternatives. Under this alternative, Refuge management consistent with 

available funding and staffing would continue. No significant changes would be initiated by the 

Service (Figure 2.1, page 2-11). 

Wildlife and Habitat. Current habitat management at Keālia Pond NWR is minimal given the large 

acreage of wetland habitat and its reliance on natural conditions that vary each year. Differences in 

weather patterns, surface and groundwater aquifers result in seasonal conditions that need to be 

supplemented with active management to provide foraging, resting, and nesting habitat for 

endangered waterbirds, to address nuisance issues, and to accomplish invasive plant control. The 

capability to manage water in the wetlands varies between habitats. Kanuimanu and Baitfish Ponds 

are constructed with levees and have independent water sources (well and sump, respectively) to 

flood water into the ponds; however, the ability to dewater the ponds is limited (e.g., lack of water 

control structures, varying pond bottom elevations). Water management in these ponds is performed 

to replicate a wet/dry cycle focusing on endangered waterbirds life history requirements. 

The seasonal, open-water main pond is subjected to the natural hydrological cycle represented by 

high water in winter (December-March), water receding April-September, and in some years, 

complete drying of the 200-acre open-water pond October-November. Current management of the 

main pond includes: pumping water from brackish water wells (2) August-December or later; and 

breaching the naturally-formed sand plug at the pond outlet when water exceeds 4.7 ft. mean lower 

low water (MLLW) and floods N. Kīhei Rd. Water naturally enters into the pond by way of three 
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West Maui Mountain streams (Pōhakea, Pale‘a‘ahu, and Waikapū), groundwater upwelling, and 

precipitation, all of which varies each year. The open water pond is void of emergent vegetation 

excluding the edge which is identified as vegetated mudflats within this CCP. Current management 

is based on the natural flooding that occurs each year, however, in most years, the Service 

supplements the wetlands from groundwater (brackish) wells. 

The main pond is the subject of seasonal nuisance issues affecting neighboring residents as biological 

and ecological processes result in large abundances of non-native insects (spotted-winged midges), 

fish die-off, and windblown sediment. In some years when the pond receives an extended high-water 

period, the invasive midge species undergo numerous generations that can result in high abundance. 

The activity of the adult phase of this aquatic insect that becomes a nuisance is primarily during 

dawn and dusk but also throughout the night. Their attraction to lights results in swarms around 

condominiums located downwind from the Refuge. The Refuge’s current method of controlling 

midges is by treating the main pond with methoprene (an insect growth inhibitor) during the peak 

abundance. Midge density is monitored each year because the population levels vary from one year 

to the next and treatment is not always necessary and can lead to resistance if used too frequently. 

The treatment with methoprene is considered to be a short-term control method while ecological 

solutions are developed. 

The second nuisance issue results from an overabundance of non-native tilapia that occurs during 

extended flood conditions in the main pond. If tilapia are not removed from the pond, when the 

water recedes significantly they die and accumulate on the downwind, south side of the pond 

producing an odor that blows to N. Kīhei Rd. and nearby condominiums. When the population is 

high, fish traps and/or nets are set during periods of receding water or the decaying fish are raked out 

of the mud to remove the biomass. 

Water level in the pond recedes naturally during summer months, creating nesting habitat for ae‘o. 

After ae‘o chicks have fledged, the pond is allowed to undergo a partial drying cycle to aerate the 

soil, break down organic material, allow dispersal of native emergent vegetation, and allow access 

for heavy equipment to perform invasive species control. Trade winds from the northeast tend to 

disperse pond sediment to the south-southeast side of the Refuge, creating dust plumes which are 

nuisance to Refuge neighbors. Control of windblown sediment is accomplished by pumping water to 

target areas along the upper north edge and allowing it to sheetflow into the center of the pond. 

Given the capabilities of water control, facilities, staffing, and funding, these methods are the extent 

of our ability to ameliorate the nuisance issues while still providing for endangered waterbirds. 

A majority of the pest species control (animal and plant) occurs within the seasonal flats located 

north of the main pond. During the dry season, September-December, Refuge staff and volunteers 

use chemical and mechanical IPM strategies to control aggressive pest plants such as: California 

bulrush, California grass, pickleweed, and marsh fleabane. Due to the lack of timed dewatering 

capabilities for the flats, mechanical treatment is limited to approximately 2 months when drying is 

sufficient to allow access of equipment. In addition, control of pest species is not as efficient because 

treated areas cannot be flooded to prevent regrowth. 

The seasonal flats at Mā‘alaea are not actively managed. The variable wet/dry cycle and lack of an 

independent water source makes it difficult to maintain water for ae‘o and shorebirds and to use IPM 

techniques effectively. In most years Mā‘alaea Flats has shallow water during the winter and dries 

out around mid-June. 
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Visitor Services. The Refuge is open year-round and visitors have access at the Kanuimanu Ponds 

and Keālia Coastal Boardwalk for wildlife viewing opportunities. Environmental education 

programs are provided by non-government organizations, Hawai‘i Nature Center and Maui Digital 

Bus, operating under Special Use Permits (SUP). Refuge staff provide information as requested, 

with emphasis on topics that supplements the teacher’s current studies. Interpretive tours are 

provided upon request. During waterbird breeding season, the Kanuimanu levees are closed (partial 

or full) to public access to eliminate disturbance to birds. To date, a closure to the coastal boardwalk 

has not been necessary because the area is dry during ae‘o nesting season; however, it may be closed 

when active nests or pre-fledgling chicks are present. 

The new Headquarters/Visitor Center (HQ/VC) at Keālia Pond NWR (funded by the American 

Recovery and Reinvestment Act) will be completed late summer/early fall 2011. There will be a 

significant increase in the number of visitors and educational groups on the Refuge which will 

require additional resources to ensure the increased wildlife-viewing remains compatible with the 

Refuge’s purpose. 

Management of Molokini, a future overlay refuge unit, would be a continuation of the previous 

stewards, DLNR, as a seabird colony with no public access. Monitoring and banding of seabird 

chicks would be maintained at the same level of 1-2 visits per year. Biological support will be a 

collaborative effort with the DLNR.

2.4.2 Alternative B: Restoration Focus 

Wildlife and Habitat. Under this alternative, the Refuge would increase the level of current 

management for habitat restoration (Figure 2.2, page 2-13). The Service will concentrate efforts on 

identifying and implementing more efficient IPM techniques to control the most aggressive invasive 

species and prepare a comprehensive restoration plan and step-down management plan with 

additional survey data, biological inventories, and identification of alternative water sources. 

Developing a water source for Mā‘alaea Flats would be prioritized to manage the water levels needed 

to accommodate ae‘o life history requirements (foraging, nesting, and breeding). 

Methods to control nuisance issues (midges, fish, and windblown sediment) will be similar to 

alternative A until the Refuge has additional capabilities to manipulate water level in the open-water 

pond. Molokini will be managed as a seabird colony with a level of monitoring limited to 2-3 visits 

per year for monitoring breeding pairs and banding chicks. Planting native species will be limited to 

no more than twice per year during the non-nesting season (December-February). The Sea Level 

Affecting Marshes Model (SLAMM) analyses will be evaluated for applicability to management 

strategies.

Visitor Services. Management of Mā‘alaea Flats would also provide enhanced wildlife viewing 

opportunities for visitors on the Keālia Coastal Boardwalk. Providing ae‘o habitat along the 

boardwalk will require additional resources to monitor human activities throughout the year, even 

when the boardwalk is closed for breeding season (i.e., law enforcement). Additional studies will be 

implemented to evaluate the impacts of visitors on the boardwalk to endangered waterbirds. The EE 

program would be enhanced through continued and expanded partnerships. 
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2.4.3 Alternative C: Wetland Capacity Focus (Preferred Alternative) 

Wildlife and Habitat As the preferred alternative, restoration efforts and increased water 

management capabilities would achieve the maximum potential for enhancing and maintaining 

biological and ecological requirements for endangered waterbirds, and indirectly benefit wintering 

migratory waterbirds (Figure 2.3, page 2-15). Under this alternative, the Refuge would plan and 

implement the physical alterations needed to maximize the ability to control water in the main pond 

and adjacent vegetated mudflats, significantly remove (or attain less than 10 percent cover) the most 

aggressive pest plants, and control larger areas of pickleweed on the flats. Physical restoration 

includes: construction of a water control structure at the N. Kīhei Rd. culvert, additional 

groundwater sources (wells) to maintain water on the flats, and reconfiguration of topography to hold 

water longer. 

The increased capability to dewater and flood the 

main pond will enable the Refuge to use water level 

to control the three nuisance issues (spotted-winged 

midges, invasive tilapia, and windblown sediment). 

Maintaining water coverage at 20-30 percent in the 

main pond December-February has resulted in the 

absence of midges and lower abundance of tilapia. 

Flooding into the adjacent sedges and flats in March 

will provide habitat for breeding ‘alae ke‘oke‘o and a 

shorter midge season. Water level would be 

maintained until natural recession occurs for ae‘o 

breeding activity. 

Molokini, after establishment as an overlay refuge, will be managed as a seabird colony with periodic 

visits to monitor the population and continue the long-term banding. The monitoring will include 3-6 

visits during seabird nesting season (March-November). In addition to maintaining consistent data 

collection for ‘ua‘u kani, the extra visits will allow us to begin an ‘ou monitoring program to 

determine the population parameters. After 3 years, the Refuge will evaluate the necessity to 

monitor annually and the potential to monitor every 2-3 years. In addition, we will initiate a native 

plant restoration plan, particularly ‘ihi (Portulaca molokiniensis) and a few other species found only 

on that islet, with a minimum of 2 additional visits per year during the non-nesting season 

(December-February). Volunteers will assist with propagating plants in the Refuge’s greenhouse and 

outplanting will be conducted by Federal and State biologists under a cooperative agreement with 

DLNR. 

The SLAMM analyses for Keālia Pond NWR will be evaluated for applicability to management 

strategies. Refuge staff will participate in development of climate change assessment protocols.

Visitor Services. Visitor services would be similar to Alternatives A and B; however, under this 

alternative the Refuge would be open on weekends and additional efforts would be made to provide 

vegetated barriers and/or blinds to provide better viewing opportunities and increase areas for 

wildlife viewing. Additional visitor services staff would provide educational programs and 

materials. Recruitment and training of volunteers to provide additional programs will increase. 

‘Alae ke‘oke‘o USFWS
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Draft Comprehensive Conservation Plan and Environmental Assessment 

2-10 Chapter 2. Alternatives, Goals, Objectives, and Strategies 

 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 2. Alternatives, Goals, Objectives, and Strategies 2-11

Figure 2.1 – Alternative A: Habitat Management 
Keālia Pond National Wildlife Refuge 

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2-12 Chapter 2. Alternatives, Goals, Objectives, and Strategies 

To preserve the quality of the map, this side was left blank intentionally.

 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 2. Alternatives, Goals, Objectives, and Strategies 2-13

Figure 2.2 – Alternative B: Habitat Management 
Keālia Pond National Wildlife Refuge 

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

To preserve the quality of the map, this side was left blank intentionally.

 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

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

Figure 2.3 – Alternative C: Habitat Management 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

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

To preserve the quality of the map, this side was left blank intentionally. 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

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

Table 2.1 - Keālia Pond NWR Management Alternatives Summary 

Keālia Pond NWR Management Alternatives Summary 

Key Themes Objectives Alt A Alt B Alt C HABITATS

Seasonal 

& Semipermanent 

Wetland 

Habitat 

1.1 Protect 

seasonal ponds 12 ac 19 ac 26 ac 

1.2 Protect 

vegetated flats 30 ac 45 ac 135 ac 

1.3 Protect open 

water 40 ac 60 ac 180 ac 

1.4 Protect 

coastal flats 0 ac 25 ac 60 ac 

Upland 

Habitat 

2.1 Enhance 

shrub land 0 ac <2 ac 5+ ac 

2.2 Protect 

buffer zone 75 ac 75 ac 79-128 ac 

Coastal 

Habitat 

3.1 Protect 

coastal strand 1 ac 2.3 ac 7 ac 

Islet 

Habitat 

4.1 Protect 

seabird nesting 5 ac 5 ac 19 ac 

Scientific 

Data

5.1 Conduct 

inventory, 

monitoring, and 

research

Monitor impacts 

of pest plants & 

animals; water 

quantity & 

quality; 

abundance of 

endangered 

waterbirds; 

seabird nesting on 

Molokini 

Track nesting 

success; impacts of 

pest plants & 

animals; water 

quantity & quality; 

abundance of 

endangered 

waterbirds; seabird 

nesting on Molokini; 

and study most 

effective IPM 

strategies 

Track nesting success; 

impacts of pest plants & 

animals; water quantity 

& quality; abundance of 

endangered waterbirds; 

monitor plants for ‘ōka‘i 

‘aiea presence; monitor 

seabird nesting on 

Molokini; study most 

effective IPM strategies; 

and conduct research on 

‘alae ke‘oke‘o intra- & 

inter-island dispersal 

patterns 

5.2 Conduct 

scientific 

assessments

Assess watershed 

volume that 

should reach 

Refuge; and 

develop climate 

change 

assessment 

protocols 

Assess watershed 

volume; assess water 

resources; assess 

bathymetric 

configurations; 

develop climate 

change assessment 

protocols; and 

evaluate SLAMM 

analyses 

Assess watershed 

volume; assess water 

resources, assess 

bathymetric 

configurations; develop 

climate change 

assessment protocols; 

and evaluate SLAMM 

analyses 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

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

2.5 Goals, Objectives, Strategies and Rationale

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

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

and the Refuge System mission. A CCP describes management actions that help bring a refuge 

closer to its vision. A vision broadly reflects the refuge purposes, Refuge System mission and goals, 

other statutory requirements, and larger-scale plans as appropriate. Goals then define general targets 

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

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

accomplish objectives. Unless specifically stated, all objectives are applicable throughout the life of 

this plan. 

In the development of this Draft CCP/EA, the Service has prepared an “effects analysis” in Chapter 7 

which evaluates alternative management actions derived from management goals, objectives, and 

implementation strategies. The goals for Keālia Pond NWR are presented on the following pages, 

followed by one or more objectives that pertain to it. The goal order does not imply any priority. 

Some objectives pertain to multiple goals and have simply been placed in the most reasonable spot. 

Similarly, some strategies pertain to multiple objectives and for clarity these strategies are listed 

under each relevant objective. Following the strategies, a brief rationale generally describes how 

management strategies will be implemented to achieve the intended objectives. The rationale may 

also, where necessary, discuss means to minimize potential impacts to non-target species and 

habitats. It also provides further background information pertaining to the importance of an objective 

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

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

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

Key Themes Objectives Alt A Alt B Alt C 

Visitor 

Services 

6.1 Provide 

opportunities for 

wildlife 

observation & 

photography

10,000 

visitors 

12,000 

visitors 

>12,000 

visitors 

6.2 Evaluate 

fishing program No program 

Complete fishing 

CD and develop 

brochures 

Complete fishing CD; 

develop brochures; 

analyze fish 

6.3 Expand 

interpretation and 

outreach 

3-5 

programs 

annually 

6-10 

programs 

annually 

>10 

programs 

annually 

Volunteers 

6.4 Expand 

volunteer 

program 

35-50 

volunteers 

51-75 

volunteers 

>75 

volunteers 

Environmental 

Education 

7.1 Expand EE 

partnerships 

1-2 

programs 

annually 

2-5 

programs 

annually 

5-12 

programs 

annually 

7.2 Expand 

internship 

program

1-2 interns 3-4 interns 4-5 interns 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

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

2.5.1 GOAL 1. Protect, maintain, and enhance seasonal and semi-permanent 

wetland habitats to meet the life history needs of endangered Hawaiian 

waterbirds. 

Objective 1.1: Protect, maintain, and enhance seasonal wetland habitat in constructed ponds. 

Protect and maintain a mosaic of seasonal wetland habitat in Kanuimanu Ponds (20 acres) and 

Baitfish Ponds (6 acres) for the life history needs of ae‘o and ‘alae ke‘oke‘o with the following 

attributes: 

 75% of pond bottom composed of undulating, irregular topography that creates exposed 

small, low islands with 4:1 slopes April-July for breeding ae‘o; 

 A mosaic of mudflat (dry and saturated) and open water (<12 in.) interspersed with 30-60% 

cover of native emergent vegetation; 

 Stable water level (1-2.5 ft. depth) in all ponds December-March for ‘alae ke‘oke‘o nesting; 

 1-4 in. open water depth, 6 in. maximum by September; 

 Predation of <5 adult ae‘o or ‘alae ke‘oke‘o documented events per year; 

 No tilapia present; 

 <25% cover of pest plants (marsh fleabane, California bulrush, and California grass); 

 Levees and slopes covered with 10-50% native groundcover vegetation with <4 in. height; 

 Abundant nektonic and benthic invertebrates with densities of 480-720 invertebrates/yd2

; 

 ‘Alae ke‘oke‘o brood rearing within 55 yds. of nesting habitat; 

 Limited public access during ‘alae ke‘oke‘o nesting December-March; and 

 Minimal human disturbance during ae‘o nesting season April-July.

Strategies for Achieving the Objective Alt A Alt B Alt C 

Kanuimanu Ponds acreage meeting objective 10 ac 15 ac 20 ac 

Baitfish Ponds acreage meeting objective 2 ac 4 ac 6 ac 

Control pest plants using mowing, brush cutting, excavation, water 

level management, prescribed fire, and herbicides (see IPM, 

Appendix E) 

  

Continue partial to complete closures to public access on levees to 

minimize disturbance to waterbirds, particularly during breeding 

season 

  

Propagate and plant native species to establish natural vegetative 

cover on pond levees and slopes 

  

Control tilapia by setting traps and nets, lowering water level, 

and/or drying the ponds August-September 

  

Use IPM techniques to set back wetland succession and promote a 

mosaic of vegetation/open water to maximize territories for ‘alae 

ke‘oke‘o 

 

Pulse water from brackish wells to inundate emergent vegetation 

for ‘alae ke‘oke‘o nesting (November)

 

Maintain water cover at 70-80% to control pest plants NovemberDecember 

 

Maintain stable water level of 1-2.5 ft. for ‘alae ke‘oke‘o JanuaryApril 

 

Pulse water during draw down to promote abundance and 

availability of invertebrates 

 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

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

Strategies for Achieving the Objective Alt A Alt B Alt C 

Slow drawdown of water to eliminate pest fish and promote 

invertebrate/algal and plant response 

 

Allow water to recede in mid-April to trigger ae‘o nesting by May  

Maintain 60-70% water coverage for breeding ae‘o  

Allow periodic dewatering from August-October to recycle 

nutrients and promote invertebrate abundance and diversity 

 

Maintain stable water level and/or pulse water slightly during ae‘o 

nesting 

 

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

water level management 

 

Control cattle egret colonies by removing roosting trees, and/or 

direct removal of individual birds 

 

Use heavy equipment to add fill and compact levees to maintain 

integrity, prevent flooding and erosion 



Use heavy equipment to reconfigure topography to increase water 

coverage 



Rationale 

Ae‘o require different loafing and foraging habitats during the breeding (April-August) and nonbreeding seasons. Recently hatched ae‘o (less than 14 days old) require shallow water of less than 2 

inches to forage. During the remainder of the year, fledglings, juveniles, and adults can forage in 

water as deep as 6 inches. Seasonally regulating water depth stimulates germination of beneficial 

plant species, controls pest plants, and provides a variety of macro-invertebrates for young and adult 

ae‘o to feed upon, thereby creating and maintaining maximized production and carrying capacity of 

the wetlands. In addition, a mosaic of open water and vegetation serves as microhabitat for ae‘o 

thermoregulation. Dewatering the pond during non-breeding season is beneficial for recycling 

nutrients, removing pest fish, and allowing staff to perform IPM (herbicide and mechanical) 

treatments before flooding. This drying cycle enhances soil aeration and invertebrate productivity. 

Breeding ae‘o require dry to unsaturated mudflat habitat for building nests. Initial (prebreeding) 

water drawdowns help establish unsaturated mudflats for nesting. Saturated mudflats can be used as 

nest sites, but results in ae‘o expending additional energy to build nests robust enough to counter the 

excess moisture. The drawdown is timed to coincide with minimal or no ‘alae ke‘oke‘o nesting or 

chick rearing, part of a cycle of wetting and drying of habitat to make it suitable to a greater number 

of birds throughout the year and increasing species diversity. Thus, ae‘o nesting habitat temporarily 

follows where ‘alae ke‘oke‘o habitat existed previously. 

The target distance between nest site to vegetation and water is approximately 5-20 feet. These slow 

breeding season drawdown rates also stimulate ample numbers and diversity of invertebrates 

throughout the brood rearing period, allowing adults with broods to establish feeding territories and 

reduce inter-brood conflicts that can result in injury or death to young chicks. 

‘Alae ke‘oke‘o prefer stable water levels (1-2.5 ft depth) for nest building and brooding. When 

preparing the pond for nesting, water levels are raised and maintained at a constant level to provide 

adequate nest sites that are secure from predation. Longer, stable hydroperiods promote epiphytic 

invertebrates (e.g., dragonflies, damselflies). In addition, fluctuating water levels would require 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

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

nesting adults to continually expend energy to build the nest up or have it isolated on dry ground and 

subject to greater predation. 

Ae‘o and ‘alae ke‘oke‘o are easily disturbed during their nesting seasons. Adults will depart the nest 

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

predators and the weather. Eggs can also be destroyed by prolonged exposure to high temperature, 

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

minimized during the nesting period to reduce the risk of nest abandonment. 

Nests, eggs, and young are vulnerable to a variety of predators including rats, mongooses, dogs, cats, 

cattle egrets, and ‘auku‘u (black-crowned night heron). Predator control success is defined, in part, 

by an increase in ae‘o nest success. During periods of higher water level management for ‘alae 

ke‘oke‘o habitat, nesting islands with surrounding water protect ae‘o eggs and chicks from cats, 

mongooses, and rats. In addition, predator control and control of pest fish species (tilapia) also 

improve habitat condition and increase nest success. Predator control during the non-breeding season 

is reliant on available staff (permanent or contracted) to monitor the program; therefore, trapping 

effort will be minimal (live traps and diphacinone bait stations) along the perimeter of the ponds. 

Low vegetation on levees creates important habitat for ‘alae ke‘oke‘o as well as other species. 

Maintaining vegetation height of less than 4 inches provides foraging areas where ‘alae ke‘oke‘o can 

graze on short grass and feed on associated invertebrates. Levees are also used as loafing habitat by 

shorebirds. Planting of native vegetation along slopes prevents erosion and also provides additional 

habitat. 

The target of removing all tilapia from the pond is attainable as no outside sources contribute directly 

to the pond (e.g., streams, reservoirs). The pond would be flooded from a groundwater well, 

precipitation, and possibly some upwelling and/or seepage from adjacent ponds. 

Objective 1.2: Protect , maintain, and enhance seasonal vegetated flats for foraging, loafing, and 

breeding. 

Protect and maintain up to 135 acres of vegetated flats for all life history (foraging, loafing, breeding) 

requirements of ae‘o and ‘alae ke‘oke‘o with the following characteristics: 

 A mosaic of flats and open water (<7 in., 1-4 in. optimal) interspersed with 30-60% cover of 

emergent vegetation and algae that provides seeds and green browse April-August; 

 No marsh fleabane, California bulrush, mangrove, or California grass; 

 Undulating, irregular bottom topography creating exposed non-saturated substrate (e.g., 

shoreline, islands) with gradual slopes; 

 <50 ft. width of emergent vegetation along shorelines for nesting ‘alae ke‘oke‘o DecemberMarch; 

 Predation of less than 5 adult ae‘o or ‘alae ke‘oke‘o documented events per year; 

 No human disturbance during breeding season, minimal disturbance remainder of year; and 

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

invertebrates (density 480-720 invertebrates/yd2

), crayfish, and small forage fish. 

   
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Draft Comprehensive Conservation Plan and Environmental Assessment 

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

Strategies Applied to Achieve Objectives Alt A Alt B Alt C 

Total acreage meeting objective characteristics 30 ac 45 ac 135 ac 

Mow and rototill to open pickleweed-dominated north shoreline 

of the main pond 

  

Use IPM strategies including mowing, brush cutting, excavation, 

water level management, prescribed fire, and herbicides 

  

Propagate and plant native species in place of pest plants to 

provide nesting structure for ae‘o and visual obscurity for ‘alae 

ke‘oke‘o territories 

 

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

water level management 

 

Manipulate water levels to expose islands for foraging waterbirds  

Flood main pond into vegetated flats in March to provide nesting 

habitat for ‘alae ke‘oke‘o 

Mow and rototill wetland habitat on the north side of N. Kīhei 

Rd. culvert to increase mudflats 



Minimize human disturbance by installing fences and signs, 

particularly along the south side of the main pond (N. Kīhei Rd.) 

by 2013 

 

Construct a water source in vicinity of the Baitfish Ponds to flood 

the vegetated flats by 2016 



Construct low berms to extend hydroperiod and promote plant 

response by 2019 

Install predator-proof fence around the wetland perimeter to 

decrease mammalian predator immigration from sugarcane fields 

by 2020 



Rationale 

Vegetated flats extend beyond the main pond (open water) around its perimeter. The flats located on 

the north side of the main pond are over 900 ft.-wide in contrast to the south side flats that are narrow 

and less than 260 feet in width. A mosaic of flats and open water (<7 in., 1-4 in. optimal) 

interspersed with 30-60 percent cover of emergent vegetation and algae provides seeds and green 

browse for ‘alae ke‘oke‘o, maximizes visual barriers for ae‘o nest territories, and provides 

concealment and thermal cover April-August. The south side is susceptible to wind generated waves 

and human trespassing; therefore, the north flats provide higher quality habitat for waterbirds. A 

majority of the management activities to control pest plants occurs on the north side during late 

summer and fall. 

Currently, we can mow and rototill to enhance vegetated flats for waterbirds but we cannot flood it 

so then the pest plants just come back. By providing a new water source and berms we would be 

able to perform our plant control and directly afterward flood the area to hold the pest plants back. 

Once we enhance habitat for waterbirds we want to limit mammalian predators by installing a 

predator-proof fence. 

The hydrology of shallow water habitats benefits breeding, resting, and loafing requirements for ae‘o 

and ‘alae ke‘oke‘o as long as dry areas adjacent to water and vegetation are available. A mosaic of 

vegetative cover created by mowing and rototilling shoreline vegetation provides thermoregulation 

cover for protection from inclement weather and pair bonding and brood rearing habitat. Based on 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

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

experience in the main pond, a long-term transition to native wetland plants and non-native waterbird 

forage plant (e.g., sprangletop and barnyard grass) species is anticipated. To keep birds from flying 

over the bridge to access the other side of the outlet, habitat enhancement on the north side of the N. 

Kīhei Rd. culvert will not be performed near the bridge, thus reducing the potential for road kill. 

Predator control efforts increase prior to and during ae ̳o breeding season around areas of high 

density nesting. Due to their vulnerability in the vicinity of primary nesting area, partial to complete 

public access closures during ae ̳o nesting/brood rearing periods increases fledging success. With 

increased habitat restoration on the flats, management of water, and effective predator control, ae ̳o 

nest success can increase from 30-60 percent. 

Objective 1.3: Protect , maintain, and enhance open water habitat for waterbird life history 

requirements.

Protect and maintain up to 180 acres of open water habitat in Keālia Pond for all ae ̳o and  ̳alae 

ke ̳oke ̳o life history requirements throughout the year with the following characteristics: 

<50 ft. width of emergent vegetation along shoreline of vegetated flats;

Open water with <12 in. depth over 30-40% of the pond during ae ̳o breeding season (AprilJuly)

>80% reduction of tilapia;

<720/yd2spotted-winged midge density;

Predation of <5 adult ae ̳o and/or  ̳alae ke ̳oke ̳o documented events per year;

Abundant epiphytic invertebrates and benthic/nektonic macro invertebrates (density of 480-

720 invertebrates/yd2), crayfish, and small forage fish; and

No human disturbance.

Strategies Applied to Achieve Objectives Alt A Alt B Alt C

Total acreage meeting objective characteristics 40 ac 60 ac 180 ac

Continue partial to complete closure of Kanuimanu ponds during 

breeding season, as needed   

Control invasive fish by deploying nets and traps to remove fish 

biomass when water recedes   

Control windblown sediment by sheetflowing water through Well 

D water distribution line August- December   

Control overabundance of spotted-winged midges with 

methoprene (no more than one treatment per year)

 

Use water control structures and well pump for water control for 

plant and invertebrate response and water manipulations  

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

water level management  

Control tilapia via chemical treatment to remnant water in the 

outlet in September 

Construct a six-bay water control structure at N. Kīhei Rd. bridge 

to control water in the main pond by 2016 

Control water in the main pond to maintain 30% cover DecemberFebruary to control midges and tilapia 

Flood main pond into vegetated flats in March to provide nesting 

habitat for  ̳alae ke ̳oke ̳o 
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Draft Comprehensive Conservation Plan and Environmental Assessment 

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

Rationale 

Flooding and dewatering in the main pond is dependent on surface and groundwater; precipitation; 

and the natural recession April-July. Water management is performed August-December (or longer 

depending on the onset of winter rains) by direct pumping from brackish water wells. There is 

limited ability to manipulate surface water in Keālia‘s main pond due to pumping capacity and 

effectiveness of proposed water control structures. 

The main pond is the primary contributor to nuisance issues (including spotted-winged midges, dead 

fish, and windblown sediment) for Refuge neighbors and yet this habitat is the most difficult to 

control. The abundance of spotted-winged midges varies from year to year but has occurred from 

mid-December to mid-April in most years. The highest abundance was approximately 96,000 

larvae/yd2. Based on monitoring and the level of complaints, we estimate 480-720 midge larvae/yd2 

is a level that is tolerable by neighbors yet provides sufficient forage for endangered and migratory 

waterbirds. The short-term control of spotted-winged midges has been an application of the insect 

growth regulator methoprene which has shown to decrease the adult nuisance. However, a natural 

long-term control is sought such as water manipulation to control midge density. 

The presence of tilapia in the main pond is inevitable even when the water coverage is less than 30 

percent because the fish remain in the outlet where the deep channel retains water throughout the 

year. During rainstorms, tilapia from upstream irrigation reservoirs enter the main pond with stream 

flow. Long periods of flooded conditions result in the dispersal of fish from the outlet and the 

exponential increase in productivity, thus leading to overcrowded conditions resulting in a fish dieoff when water level recedes to approximately 50 percent coverage. The main pond is allowed to dry 

September-December for regrowth of kaluhā (saltmarsh bulrush), breakdown of organic material, 

soil aeration, and dispersal of accumulated sediment. 

Beginning in 2001, an in-depth study of the pond hydrology (quantity and quality) was conducted in 

addition to monitoring spotted-winged midges and tilapia abundance. Monitoring data from 2 years 

with low winter water level December-February resulted in midge numbers below nuisance level. 

Duplication of this water condition during key months (December-February) may be a long-term 

solution to controlling midges and tilapia. In most years, midge abundance was high when winter 

flooding was high (December-April). However, when water level was low and the salinity was high, 

the midge abundance was less and not a nuisance to neighbors. If water pumping capability is 

maximized and the water control structure at the N. Kīhei Rd. bridge is constructed, the ability to 

maintain low water conditions (20-30 percent coverage) from the time winter flooding occurs to end 

of February may be the solution to both controlling the abundance of midges and also the abundance 

of tilapia. The shallow, salty water conditions and disconnect from the pond outlet results in 

undesirable habitat for tilapia, thus their abundance would be controlled. 

Lessening the windblown sediment nuisance issue is also an attribute of water control. Water can be 

directed to the upper reaches of the main pond via the Well D water distribution line to sheet flow 

over extensively dry portions to hold down sediment. This would be performed after ae ̳o breeding 

season September-December and after IPM treatments on pest plants along the vegetated edge has 

been completed.
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

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

Objective 1.4: Protect , maintain, and enhance coastal flats for ae‘o life history needs. 

Protect and maintain up to 60 acres of seasonal coastal flat habitat at Mā‘alaea Flats for all life history 

requirements of ae‘o throughout the year with the following characteristics: 

 A mosaic of saturated and dry mudflats; 

 Open water <1 in. depth; 

 Documented predation level of <5 ae‘o nests annually; 

 No human disturbance within 109 yards of breeding territories; 

 Abundant invertebrates with densities of 480-720 invertebrates/yd2

; 

 <30% cover of vegetation to provide cover and protection from wind; 

 <30% cover of pickleweed; 

 50-100 ft. width of vegetation along N. Kīhei Rd.; and 

 Physical barriers to prevent vehicular access onto the coastal flats. 

Strategies Applied to Achieve Objectives Alt A Alt B Alt C 

Total acreage meeting objective characteristics 0 ac 25 ac 60 ac 

Maintain recycled-plastic fence along N. Kīhei Rd. to prevent 

vehicular access onto the flats 

  

Construct water source (well, pump, water distribution line) at 

Mā‘alaea Flats to maintain shallow water by 2014 

 

Implement complete or partial closure of boardwalk, if necessary 

to prevent abandonment and egg/chick predation 

 

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

water level management 

 

Map topography of the mudflats to identify areas to construct low 

berms for water retention by 2013 

Use IPM strategies including mowing, brush cutting, excavation, 

water level management, prescribed fire, and herbicides to control 

pest plants 

 

Propagate and plant native species in place of invasive plants 

Create low islands within the flats to diversify topography by 

2016 

Restore Mā‘alaea Flats wetland community to provide additional 

habitat away from the boardwalk by 2013 

Alter bathymetry to retain water longer on Mā‘alaea Flats by 2013 

Plant native shrub buffer along highway to reduce opportunities 

for waterbirds flying low over road by 2014 

Rationale 

Mā‘alaea Flats is connected to the main pond outlet on the east side and receives ocean water during 

higher high tides on the west end of the 60 acre flats. Natural flooding December-March appears to 

be from high water levels in the main pond via the outlet. If the Refuge had the ability to maintain 

water on the flats, there would be a increase in ae‘o use throughout the year. An additional source of 

water would enable the Refuge to maintain shallow water until completion of the breeding season. In 

addition, low berms on the east side, adjacent to the outlet would retain water on the flats instead of 

draining into the main pond outlet, particularly when the sand plug is breached (naturally or by 

hand). Monitoring human activities is a continuous need because of the connection to the beach front 

and isolation. Signage and fencing is necessary to control human access and law enforcement is 

essential to prevent disturbance to birds even during boardwalk closures.
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

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

2.5.2 GOAL 2. Expand protected species’ habitat to promote their recovery. 

Objective 2.1: Enhance shrub land habitat for endangered ‘ōka‘i ‘aiea (Blackburn’s sphinx 

moth). 

Enhance plant community to provide habitat for the endangered ‘ōka‘i ‘aiea with the following 

characteristics: 

 1-5 acres of dry to mesic shrub land and forest habitat; 

 60-80% native host plants including ‘aiea, lama, hao, ‘ohe, ‘āla‘a, ‘a‘ali‘i, wiliwili, maiapilo, 

and naio; 

 <40% pest groundcover plants and annual grasses; 

 10-30% tree tobacco; and 

 Restrictions on public access to inhibit collection. 

Strategies Applied to Achieve Objectives Alt A Alt B Alt C 

Total acreage meeting objective characteristics 0 ac 0-2 ac 5+ ac 

Identify presence, location, and extent of plant species known to 

be used by ‘ōka‘i ‘aiea 

 

Monitor plants for evidence of ‘ōka‘i ‘aiea activity (eggs, 

larvae, adults) 

 

Use IPM techniques to remove pest plants (kiawe, marsh 

fleabane) around host species such as tree tobacco 

 

Conserve native plants known to host ‘ōka‘i ‘aiea , including 

lama, hao, ‘ohe, ‘āla‘a, ‘a‘ali‘i, wiliwili, maiapilo, and naio 

Propagate and plant native host species 

Rationale 

The ‘ōka‘i ‘aiea moth is currently found in association with topographically diverse landscapes that 

contain low to moderate levels of non-native vegetation. Vegetation types that support ‘ōka‘i ‘aiea 

include dry to mesic shrub land and forest from sea level to mid-elevations (USFWS 2003). Impacts 

to the moth’s habitat from urban and agricultural development, invasion by non-native plant species, 

habitat fragmentation and degradation, increased wildfire frequency, ungulates, and direct impacts to 

the moth from non-native parasites and insect predators have reduced the species’ range. 

Most common native plants that the moth use are lama trees, hao, ‘ohe, ‘āla‘a trees, ‘a‘ali‘i, wiliwili, 

and naio. The largest populations of ‘ōka‘i ‘aiea on Maui and Hawai‘i are associated with trees in 

the genus Nothocestrum (i.e. tree tobacco). The necessary biological requirements of ‘ōka‘i ‘aiea 

larvae for foraging, sheltering, maturation, and dispersal are the two documented host plant species 

within the endemic Nothocestrum genus (N. latifolium and N. breviflorum) and the dry and mesic 

habitats between the elevations of sea level and 5,000 feet and receiving between 10-100 inches of 

annual precipitation which currently support or historically have supported these plants. 

Although only a few ‘ōka‘i ‘aeia have been reported at Keālia Pond, the Refuge has the potential to 

meet these requirements for both adult and larvae. A closely associated State wetland management 

area, Kanaha Pond, is identified as such habitat.

   
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

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

Objective 2.2: Expand Refuge boundary to maintain a buffer from upper watershed impacts. 

Maintain 75 acres of upland habitat along the Refuge boundary to serve as a buffer from future land 

use changes and protect wetland habitat from upper watershed impacts (filter pollutants, suspended 

sediment, pest plant species from streams entering into the wetlands). Expand the Refuge boundary 

to incorporate additional wetland habitat and upland habitat for the benefit of protected species (ae‘o, 

‘alae ke‘oke‘o, honu, honu ‘ea, and seabirds) and wetland integrity. 

Strategies Applied to Achieve Objectives Alt A Alt B Alt C 

Total acreage meeting objective characteristics 75 ac 75 ac 79-128 ac 

Maintain 75 acres of upland habitat along the Refuge’s north 

boundary with forest, scrub-shrub, and grasses to minimize 

sedimentation from upper watershed 

  

Acquire 9-34 acres of coastal wetlands at Mā‘alaea Flats from 

Alexander & Baldwin (A&B) to make the wetland a contiguous 

property 

 

Acquire kūleana property (approximately 4 ac) located along the 

Refuge’s southeast boundary 

Acquire 5-7 acres of coastal dune habitat as a conservation 

easement, from Keālia Resort in North Kīhei to the Refuge’s 

western boundary at Mā‘alaea Flats 

 

Evaluate the feasibility of expanding the Refuge’s north boundary 

(5-8 ac) to incorporate additional upland habitat as buffer around 

the wetlands 

 

Evaluate the feasibility of acquiring Keālia coastal dunes at 

Mā‘alaea Flats 

Rationale 

The north side of the Refuge is comprised of upland vegetation and shrub habitat which provides a 

buffer and filter for sheet flow runoff into Keālia Pond (e.g., slows down water and allows 

groundwater seepage, filters sediments and pollutants before entering the vegetated mudflats and 

open water). This area is dominated by dense stands of pest plant species (e.g., kiawe, salt cedar, 

Java plum, milo, castor bean, haole koa). While native plants are desirable, the existing vegetation 

provides an adequate buffer to shield endangered waterbird habitats from urban disturbances. 

Suspended sediments contained in stream flows from the upper watershed primarily derive from 

sugarcane production and urban development and settle in the Refuge wetlands. Acquisition of 9-34 

acres beyond the current boundary at Mā‘alaea Flats would effectively encompass the remaining 

wetland and peripheral buffer of forest/shrub habitat on north side and coastal dunes on the south 

side. A portion (9.4 ac) of this area is within the approved Refuge boundary. 

We have initiated discussions with the land owners for specific land parcels adjacent to Mā‘alaea 

Flats and the Refuge’s southeast boundary and those would be the first priority for acquisition. A 

land protection planning effort, including public input and NEPA compliance, is required for any

boundary expansion. 

 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

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

2.5.3 GOAL 3. Protect, restore, and manage coastal habitat for the benefit 

of nesting sea turtles, seabirds, and the integrity of the fragile 

ecosystem. 

Objective 3.1: Restore and maintain coastal strand and dune habitat. 

First restore and thereafter maintain 2-3 acres of the coastal strand and dune habitat for the benefit of 

nesting sea turtles (primarily honu ‘ea) and nesting seabirds (‘ua‘u kani), and also to provide a 

protective barrier to Mā‘alaea Flats. The coastal dune and beach strand habitat will be restored and 

maintained for the following characteristics: 

 Patchy distribution of low-growing (2-8 ft), native woody species (e.g., ‘ilima, naupaka 

kahakai, pilo, wiliwili, naio, hala) as a mosaic; 

 30-40% cover of native grasses (e.g., ‘aki‘aki) and herbaceous vegetation (e.g., ‘akulikuli, 

beach morning glory, kīpūkai) on dunes; 

 <25% of woody invasive plant species (e.g., marsh fleabane, kiawe, and koa haole) in coastal 

strand; 

 <25% cover of herbaceous invasive plant species (e.g., saltbush) and grasses (buffelgrass, 

swollen finger grass); 

 Manage public use to reduce human disturbance during turtle nesting season; and 

 Documented predation of no more than 1 seabird nest annually. 

Strategies Applied to Achieve Objectives Alt A Alt B Alt C 

Total acreage meeting objective characteristics 1 ac 2.3 ac 7 ac 

Continue partnership with A&B with installation and maintenance 

of plastic fence along Keālia Beach to prevent erosion of sand 

dunes by vehicles 

  

Resume Kokua Keālia project to restore native coastal plants to the 

dunes adjacent to the boardwalk by 2012 

 

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

water level management 

  

Consult with State and/or County Coastal Engineers to identify 

climate change impacts and evaluate alternatives to enhancing 

coastal habitat 



Coordinate with adjacent landowners for water source to irrigate 

plants during establishment phase, if necessary 



Propagate native plants (‘akulikuli, pauhoehoe, ‘ākia, naupaka, 

nanea, ‘ōhelo kai) in Refuge greenhouse for outplanting 

  

Install temporary sand fencing to facilitate restoration of impacted 

dunes 



Consult with coastal specialists on the future impacts of climate 

change to habitat along Keālia Beach 

  

Use appropriate IPM techniques (chemical, mechanical, manual) 

that would not result in additional erosion to control invasive or 

undesirable plant species 



   
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

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

Rationale 

Coastal dune communities are important to several rare and endangered plant and potentially animal 

species. Coastal dunes are also fragile and easily altered by human activity. Coastal dune and beach 

strand habitat also provides important foraging and loafing habitat for migratory bird species such as 

the ‘ūlili (wandering tattler), kōlea (Pacific golden plover), hunakai (sanderling), and ‘akekeke 

(ruddy turnstone). Given the soil texture, relative position to the shoreline, and desirable plants 

species; the strand provides suitable subterranean nest burrow habitat for ‘ua‘u kani and ‘a‘o. This 

coastal habitat is also suitable for ‘ilio-holo-i-ka‘ua‘ua pupping and rearing and by honu ‘ea and honu 

for laying eggs and basking. 

Restoration of coastal dunes not only promotes habitat quality, it also enhances visitors’ experience 

along the Keālia Coastal Boardwalk. Native species will be planted during the winter season to 

minimize the need to water during the establishment phase. Planting will not be performed when 

endangered birds are nesting. The dense vegetative growth of invasive plants have provided an 

effective buffer between the ocean and Mā‘alaea Flats therefore, careful planning and scheduling is 

needed to ensure the integrity and stability of the beach and dunes is not impacted during control and 

replanting efforts. 

This section of the coastal strand and dune system is located at a greater distance from human 

activity with fewer human impacts. The area is ideal for nesting sea turtles (no headlights or 

condominium lights) and seabirds, in addition to ae‘o and migratory shorebirds on the mudflats.

2.5.4 GOAL 4. Protect, restore, and manage offshore islet habitat for 

seabird nesting. 

Objective 4.1: Protect, restore, and manage Molokini for seabirds. 

Protect and restore up to 19 acres on Molokini for breeding seabirds, primarily ‘ua‘u kani (wedgetailed shearwater), and ‘ou (Bulwer’s petrel) with the following characteristics: 

 >30% native vegetation; 

 50-80% ‘ua‘u kani fledging success; 

 No non-native predators; 

 No public access onto the islet; 

 Researchers access on islet from April-early November only. 

Strategies Applied to Achieve Objectives Alt A Alt B Alt C 

Total acreage meeting objective characteristics 5 ac 5 ac 19 ac 

Maintain Memorandum of Understanding with DLNR 

Finalize Memorandum of Understanding with the U.S. Coast 

Guard 

  

Establish quarantine protocols for agency access   

Conduct seabird banding 1-2 

visits/year 

2-3 

visits/year

3-6 

visits/year

Propagate and plant native species during non-breeding season 

(December-February) during the rainy season 

 

Conduct ‘ua‘u kani breeding bird survey  

   
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

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

Rationale 

Molokini will be established as an overlay refuge unit of Keālia Pond NWR until such time when the 

USCG releases the property to the Service. Public access on the island has been limited since the 

early 1900s due to the sensitivity of burrowing seabird nest sites. Due to this, the seabird habitat is 

intact and very successful. This closure to public access, excluding Refuge and State staff, will be 

retained within each of the alternatives. 

The potential for native plant restoration is high, even with the access logistics (boat transportation, 

terrain), because the Refuge has volunteers to propagate plants in the greenhouse and references to 

historic (1913) and recent botanical surveys are available to replicate native species including: ‘ihi, 

alena, nena, pili grass, pa‘u o hi‘iaka, nehe, ‘ōhelo kai, ‘akulikuli, ‘ilima, and uhaloa. 

A cooperative agreement with DLNR is essential to retain the consistency of management efforts, 

transfer of information, and expertise.

2.5.5 Goal 5. Gather scientific information in support of adaptive 

management decisions on the Refuge under Goals 1-4. 

Objective 5.1: Conduct inventory, monitoring, and research to document progress and evaluate 

management strategies to guide management decisions. 

Throughout the life of the CCP, conduct high-priority inventory and monitoring (survey) activities 

that evaluate resource management and public use activities to facilitate adaptive management. These 

surveys contribute to the enhancement, protection, use, preservation, and management of wildlife 

populations and their habitats on- and off-refuge lands. Specifically, they can be used to evaluate 

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

following attributes: 

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

zero to minimal habitat destruction; 

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

macroinvertebrates, vertebrates) to meet statistical analysis requirements for identification 

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

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

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

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

and applicable. 

Inventory, monitoring, and research – Keālia Pond Alt A Alt B Alt C 

Inventory and monitor bird abundance with monthly census to obtain mean 

count and trends 

  

Monitor breeding ‘alae ke‘oke‘o from December-March for reproductive 

success 

  

Monitor breeding ae‘o from April-July for reproductive success   

Monitor macroinvertebrate densities   

Monitor mongoose and rat abundance with tracking tunnel surveys at least 

every 60-90 days 

  

Monitor and document predation of waterbirds   

Monitor banded ae‘o and ‘alae ke‘oke‘o   
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

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

Inventory, monitoring, and research – Keālia Pond Alt A Alt B Alt C 

Monitor midge larvae by core sampling during high water conditions 

(December-April) 

  

Monitor water quantity (surface water and groundwater)   

Monitor water quality (abiotic parameters: pH, temperature, salinity, 

conductivity, turbidity, dissolved oxygen) 

  

Maintain and monitor weather station   

Monitor fish abundance  

Monitor vegetation response to IPM techniques  

Monitor waterbird response to IPM strategies by sampling treated and 

untreated habitat 

 

Conduct study to determine the most effective IPM strategies to control 

California bulrush and other invasive species 

 

Research to determine invertebrate composition and relative abundance in 

vegetated mudflats and open water habitats 

 

Determine invertebrate composition and relative abundance at Mā‘alaea 

Flats 

 

Monitor human activities along the coastal mudflats and dunes for potential 

effects that jeopardize the integrity of the area 



Monitor birds by satellite telemetry 

Periodically monitor macroinvertebrate densities 

Periodically (once per 10 years) collect/analyze soil samples for 

contaminants, including streamflow entry areas 



Identify presence, location, and extent of plant species known to be used by 

‘ōka‘i ‘aiea 

Monitor plants for evidence of ‘ōka‘i ‘aiea activity (eggs, larvae, adults) 

Conduct research on ‘alae ke‘oke‘o intra- and inter-island dispersal patterns 

using satellite telemetry 

Conduct study to identify alternative methods to control tilapia (reduce 

catch per unit effort) 

Conduct research on ‘alae ke‘oke‘o movements and dispersal using satellite 

telemetry 

Analyze fish to ensure they are safe for human consumption in potential 

fishing program (through Department of Health) 

Implement a pilot program to evaluate the impacts of a fishing program at 

the main pond 

Inventory, monitoring, and research – Molokini Alt A Alt B Alt C 

Contract a complete archaeological and cultural investigation for Molokini 

when acquired as overlay refuge 

 

Determine the breeding population of ‘ou on Molokini  

Monitor active nesting attempts by ‘ua‘u kani and ‘ou (February-March) 

Monitor ‘ou breeding (March) 

Monitor ‘ua‘u kani nest success and band chicks (October) 

Monitor and document seabird predation 

   
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

2-32 Chapter 2. Alternatives, Goals, Objectives, and Strategies 

Rationale 

The Administration Act requires us to ‘‘... monitor the status and trends of fish, wildlife, and plants 

in each Refuge.’’ Surveys are used primarily to evaluate resource response to assess progress toward 

achieving Refuge management objectives derived from the Refuge System mission, Refuge purpose, 

and maintenance of biological integrity, diversity, and environmental health. Determining resource 

status and evaluating progress toward achieving objectives is essential to implementing adaptive 

management on DOI lands as required by policy (522 DM 1). Surveys would provide the best 

available scientific information to promote transparent decisionmaking processes for resource 

management over time on Refuge lands. 

Inventory, monitoring, and research studies are essential to high-quality habitat and population 

management. Conducting censuses for endangered waterbirds and compiling data is critical to 

evaluate population status and measure progress towards goals. Similarly, other populations, habitat 

conditions and habitat management practices, including restoration efforts must be monitored to 

evaluate their status and effectiveness. Population trends can be used to evaluate habitat 

effectiveness and guide management actions. When Molokini is acquired as an overlay refuge, a 

cultural and archeological investigation will be contracted to obtain information about the human 

history of the Islet. It will seek to answer various questions about the pre-contact activities of Native 

Hawaiians and their interactions with the natural resources surrounding the Islet. It can also help to 

ascertain the chronology of pre-historic times. 

Refuges must collect site-specific information and conduct defensible research to provide 

information for devising, guiding and adapting management practices. Monitoring habitat conditions 

provides valuable support and sound decision-making as applied to Refuge resource management. 

Applied research on the Refuge will help address management issues and questions, in theory, will 

result in improved management decisions on both the Refuge and on a regional basis. The Refuge 

has always maintained a close working relationship with State and local agencies, and universities to 

advance the knowledge base of a variety of habitats and plant and wildlife species. We have been 

monitoring environmental parameters (water, weather), vegetation, waterbirds, and invertebrates, to 

varying degrees, for the past 10 or more years and will continue to maintain consistent methodology 

in data collection. These data have provided baseline information for management planning to 

optimize habitat for endangered waterbirds, address nuisance issues, and evaluate adaptive 

management strategies. 

The Refuge's location at the base of the watershed makes the wetlands vulnerable to impacts from 

upper land use activities. Periodic analyses of water and soils is a preventative measure to identify 

contaminants and trace elements, and changes in what is entering into the Refuge property. Some 

elements attach to soils but are not found in water, and vice versa; therefore, the need to sample both 

in order to gain a broader picture of upper watershed impacts. Although soils can retain 

contaminants over a period of time, water samples detect only one point in time but if collected 

during similar conditions (high water flow from streams), the data provides a sufficient index for 

long term monitoring. 

Opening the Refuge to a seasonal fishing program is in a preliminary planning phase. A fishing 

program would primarily be a management activity but can be an opportunity to involve the public, 

with the stipulation that it does not negatively impact the endangered Hawaiian waterbirds. Time 

and staff are needed to plan, complete policy requirements, and coordinate logistics of operating a 

fishing program. Volunteers will be needed to oversee the participants.   
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

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

Objective 5.2: Conduct scientific assessments. 

Throughout the life of the CCP, conduct scientific assessments to provide baseline information to 

expand knowledge regarding the status of Refuge resources to better inform resource management 

decisions. These scientific assessments will contribute to the development of Refuge resource 

objectives and they would also be used to facilitate habitat restoration through selection of appropriate 

habitat management strategies based upon site-specific conditions. These assessments have the 

following attributes: 

 Utilize accepted standards, where available, for completion of assessments; and 

 Scale and accuracy of assessments are appropriate for development and implementation of 

Refuge habitat and wildlife management actions. 

Strategies Applied to Achieve Objectives Alt A Alt B Alt C 

Based on the topography of the main pond, evaluate the need to 

periodically excavate and reconfigure elevations to facilitate water 

management (flooding and dewatering capabilities) 

 

Evaluate feasibility of using a pump at the pond outlet for water 

control (lowering water level) 

Identify the quantity of water from the Pōhākea, Pale‘a‘ahu, and 

Waikapū streams that should reach the Refuge 

  

Conduct soil investigation to identify composition and profile and 

use data and hydrological processes information to reconfigure 

topography in order to retain water for foraging and nesting ae‘o 

 

Evaluate the topography of Mā‘alaea Flats and identify methods to 

separate from outlet (berm and possible water control structure) 

 

Collect and analyze soil (composition, profile) at Mā‘alaea Flats 

Evaluate SLAMM Analyses for climate change planning  

Conduct a biological assessment on Molokini (non-native 

amphibians, invertebrates) 

Conduct a vegetation assessment (composition, relative abundance) 

on Molokini 

Rationale

Appropriate environmental assessments are necessary to determine resource status, promote learning, 

and evaluate progress toward achieving objectives whenever using adaptive management. These 

assessments would provide fundamental information about biotic (e.g., vegetation data layer) as well 

as abiotic processes and conditions (e.g., soils, topography) that are necessary to ensure that 

implementation of on-the-ground resource management achieve resource management objectives 

identified under Goals 1-4. 

A comprehensive hydrological assessment is needed to evaluate wetland needs and upper watershed 

land-use changes. Three streams drain from 56-square miles of the West Maui Mountain watershed 

and one additional stream drains a portion of the Haleakalā watershed into Keālia Pond. These 

stream flows are unpredictable and uncontrolled. but its flow is also infrequent and unpredictable. 

Preliminary data exists on the amount of surface water these streams deliver, however, further 

assessment is also needed to determine the amount (acre-feet) of stream flow that is required to 

maintain water level at a suitable depth to manage for ae‘o and ‘alae ke‘oke‘o throughout the year. 

Changes in the upper watershed can have potential impacts to the Refuge in terms of water quality 

and quantity; therefore, a more accurate assessment on these parameters is needed to ensure water is 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

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

available for endangered and migratory bird species. Water and sediment samples from streams were 

collected and analyzed in 2003 and provide a baseline for future monitoring of water quality entering 

into Keālia Pond. Baseline and future monitoring of water entering into the Refuge is a necessity as 

land use changes occur and water issues arise on Maui. The function as a settling basin has created 

the endangered waterbird habitat for which the Refuge was established and thus, should be retained 

as much as possible. If streamflow subsides in the future, the Refuge would need to pump water 

from the brackish water wells throughout the year to replicate natural conditions. This would not 

only be costly, but also difficult to achieve for such a large wetland. 

Mā‘alaea Flats is partially flooded with water from the outlet when the main pond is full. This 

hydrological connection means that when the sandplug is breached (naturally or manually) water in 

the flats drains as well. This has a negative impact on waterbird foraging and nesting habitat on the 

flats. Planning, including evaluation of the elevational gradient and a new soil survey, is needed to 

identify methods to hold water on the flats and maintain the level for ae‘o foraging and nesting. 

Molokini will be a new addition to the Refuge System and although the island was managed by 

DLNR, their activities were limited to monitoring ‘ua‘u kani nesting. A biological and vegetation 

assessment is needed prior to restoration planning initiation. There is a high potential to re-establish 

native plants and the capability of replicating the plant composition recorded in 1913. The known 

seabirds that use the islet for nesting are burrowers and ground nesters; therefore, an inventory of 

invertebrates is needed to ensure non-native species (e.g., big-headed ants and yellow crazy ants) will 

not negatively impact chick survival. 

2.5.6 GOAL 6. Through quality wildlife-dependent recreation and learning 

opportunities, visitors understand and appreciate the unique wildlife 

and habitats of Keālia Pond NWR. 

Objective 6.1: Provide opportunities for wildlife observation and photography. 

Provide visitors with the opportunity for self-guided wildlife observation and photography to 

increase their knowledge and appreciation for wetland ecosystems and endangered species. 

 Focus on wetland ecology and the endangered waterbirds that rely upon these wetlands; 

 Provide viewing opportunities from outside the fence when the Refuge is unstaffed; and 

 Directly link opportunities to EE and interpretation programs. 

Strategies Applied to Achieve Objectives Alt A Alt B Alt C 

Annual viewing opportunities at Kanuimanu Ponds 10,000 12,000 > 12,000 

Annual viewing opportunities at Keālia Coastal Boardwalk 6,000 6,000 6,000 

Visitor Center Use 10,000 12,000 15,000 

Maintain safe access on all trails and Keālia Coastal Boardwalk 

by performing periodic inspections and repairs 

  

Install trail counter   

Annually evaluate and implement a closure of the Keālia 

Coastal Boardwalk during ae‘o nesting season, if necessary 

  

Monitor waterbird response to visitor use to minimize potential 

impacts to the species and adapt visitor use patterns 

  

Complete the Complex brochure and bird species checklist   

   
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

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

Strategies Applied to Achieve Objectives Alt A Alt B Alt C 

Coordinate with HDOT to establish a bus stop at the coastal 

boardwalk between Mā‘alaea and Kīhei 

  

Continue to accommodate recreational photographers visiting 

the Refuge and support existing agreements 

  

Open Kanuimanu Ponds to the public on weekends  

Within 5 years, develop and implement a Visitor Services Plan 

(VSP) and associated Transportation Plan 

 

As part of the VSP, design and construct a boardwalk from the 

HQ/VC to Kanuimanu Ponds 

 

As part of the VSP, develop a SUP for commercial 

photographers with standardized procedures and fee schedule 

As part of the VSP, evaluate the need, location, and logistics of 

photo blinds on/adjacent to Kanuimanu Pond levees 

Evaluate the potential for fee program on the Refuge 

Rationale 

The Keālia Coastal Boardwalk is open year-round for visitors, but tours are only provided upon 

request. The parking area will only accommodate 12 vehicles, 2 disabled parking, and 2 buses; 

therefore, it may be advantageous to have the boardwalk as one of the stops for public transportation 

when traveling from west (Lahaina) to east (Kīhei). As long as the period between stops is adequate, 

it may be a way to reach more people given the limited parking capacity. 

Keālia Pond NWR has been more visible to the public since the opening of the boardwalk. Visitor 

use will increase significantly when the new HQ/VC is opened to the public. The Refuge relies on 

static displays for self-guided visitation; however, additional opportunities for visitors and 

educational groups are expected in the future. The step-down VSP is intended to enhance visitors’ 

knowledge of the value of wetlands, offshore islands and the wildlife that depend on their existence, 

and native Hawaiian traditional uses. 

Keālia Pond NWR hosts hundreds of migratory waterfowl and shorebirds during winter months and 

receives most of its visitors during that same period. With increased water control capabilities, the 

Refuge will have some flexibility with attracting wetland birds into accessible areas for wildlife 

observation. During the nesting seasons for endangered ‘alae ke‘oke’o (December-May) and ae‘o 

(April-August), continuous evaluation of waterbird use is conducted so Refuge staff can allow access 

to visitors where birds remain undisturbed. Accessibility onto Kanuimanu Pond levees gives 

photographers an opportunity to photograph wetland bird species. The size of the main pond and 

background with the West Maui Mountains makes a scenic shot, particularly in the morning when 

the sun’s glare is low and the trade winds are light. 

Recreational photographers have provided the Refuge with bird photographs for brochures by means 

of SUP and the photographer’s approval to use his/her photographs. This has worked well in the past 

and benefits the Refuge. Recreational photographers can access general public use areas (Kanuimanu 

Pond levees and the boardwalk) and are usually not identified upon check-in at the visitor contact 

station (HQ). Increased visitation will require more law enforcement presence to protect wildlife and 

minimize vandalism. As an example, the Keālia Coastal Boardwalk is the target of graffiti, 

destruction of property, trash dumping, and camping. Illegal access to areas not open to the public 

can have detrimental impacts on waterbirds and vegetation (additional introduction of pest species). 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

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

Public access onto Molokini is prohibited due to the sensitivity and geology of the island. There are, 

however, tour boat companies that provide snorkeling/diving opportunities in the surrounding waters 

(designated a State marine preserve), outside our jurisdiction. Access will be given to Federal and 

State biologists performing Refuge duties. The Refuge brochure will mention Molokini as part of the 

Refuge System. Special Use Permits to access other areas are issued on a case-by-case basis if 

compatible. 

Objective 6.2: Evaluate feasibility of a recreational fishing program. 

Within 5 years of plan approval, investigate, research, and evaluate the compatibility of a seasonal 

fishing program as a management tool for controlling pest species (tilapia). 

Strategies Applied to Achieve Objectives Alt A Alt B Alt C 

Determine the compatibility of fishing at Keālia Pond  

Prepare materials related to fish ecology in Keālia Pond, (i.e., fish 

identification, biology, and impacts of pest species) 

 

Evaluate whether or not a fishing program is an effective 

management tool for removing biomass 

Analyze fish for contaminants and human consumption (Dept. of 

Health) 

Define the Refuge’s role and participation in the State Fishing 

Education Program 

Rationale 

The Refuge hosted the State Fishing Education Program (an annual public education event) from 

1997-2002 at Kanuimanu Ponds. The intent of this objective is to evaluate the need (compared with 

other management strategies to remove tilapia), compatibility, and feasibility of conducting a 

controlled public fishing program. Other aspects that need to be considered are law enforcement, 

safety, operating requirements (staffing), and outreach to the public. For the latter, the potential for 

illegal fishing during “off-season” is a greater concern. A fishing program would primarily be a 

management activity but can be an opportunity to involve the public, with the stipulation that it does 

not negatively impact the endangered Hawaiian waterbirds and migratory birds. Time and staff 

would be needed to plan, complete policy requirements, and coordinate logistics of operating a 

fishing program. 

 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

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

Objective 6.3: Provide interpretation and outreach programs. 

Expand the Refuge’s interpretation and outreach programs to foster appreciation and stewardship for 

wetland and cultural resources. Provide interpretive tours for visitors, birding groups, and other 

educational groups. 

Strategies Applied to Achieve Objectives Alt A Alt B Alt C 

Annual number of programs 3-5 6-10 >10 

Maintain high-quality, updated displays and signs for Keālia 

Coastal Boardwalk and trails to interpret the ecology, wildlife, 

and identification of wetland habitats and associated watersheds 

  

Provide public presentations and interpretive tours on wetland 

ecology and wildlife, coastal habitats, and cultural history 

  

Keep the Refuge website updated on available opportunities and 

current projects 

  

Provide public presentations and interpretive tours on wetland 

ecology and wildlife, coastal habitats, and cultural history 

  

Prepare a pamphlet on Molokini for distribution to tour boat 

operators/companies 

Incorporate Refuge opportunities and information into the Maui 

Visitors’ Bureau products 

Participate in off-site community programs including Earth Day, 

beach cleanups, watershed events, etc. 1-2/year 1-4/year 3-6/year

Rationale 

Interpretation is intended to create emotional and intellectual connections between the audience and 

the resource as well as provide opportunities for visitors to make their own connections to the 

resource. Outreach is two-way communication between the Service and the public to promote 

involvement with the Refuge, and influence attitudes and actions, with the goal of improving joint 

stewardship of our natural resources. We rely heavily on self-guided opportunities for visitors. This 

is especially true for the Keālia Coastal Boardwalk which is approximately 2 miles from the HQ/VC. 

Offering special talks at the boardwalk by volunteers will enhance visitors’ knowledge and 

understanding and encourage visitors to return. Volunteers may also assist with interpretation at 

Kanuimanu Pond, particularly for school groups or to lead groups of birdwatchers. The new Keālia 

Pond HQ/VC is designed to prepare visitors for and enhance their experience on the Refuge. 

Molokini is not accessible due to the sensitivity of the habitat and safety; however, informative 

materials and interpretation of the property will be given to Refuge visitors, tour boat operators, and 

others to develop awareness for seabird habitats. 

We would like to increase outreach to direct more attention to the Refuge as an outdoor learning 

experience. Specialized tours could be developed to meet the needs of the public. This will increase 

the Refuge’s visibility as part of the community where people can explore the natural resources and 

gain a sense of stewardship in becoming involved with Refuge programs. 

 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

2-38 Chapter 2. Alternatives, Goals, Objectives, and Strategies 

Objective 6.4: Expand volunteer opportunities and partnerships. 

Expand the Refuge’s volunteer program to foster appreciation and stewardship for the wetland 

resources and assist with Refuge activities and facilities. Participate in partnerships and other 

collaborative efforts that provide ecosystem-based opportunities to facilitate Refuge objectives. 

Strategies Applied to Achieve Objectives Alt A Alt B Alt C 

Annual volunteers 35-50 51-75 >75 

Continue to support volunteerism through partnerships and 

community groups 

  

Post available opportunities and current projects on website   

Continue partnerships with community organizations, County, 

State, and Federal agencies related to watersheds, wetland and 

coastal restoration, etc. 

  

Establish a Friends group to promote and assist with the 

Refuge’s purpose and mission 

 

Incorporate Refuge volunteer opportunities into State and 

County volunteer programs and Maui Visitors’ Bureau products 

Recruit and train volunteers to assist with visitors and school 

groups, particularly during peak hours 

Seek volunteers to offer special programs at the kiosks of the 

Keālia Coastal Boardwalk 

Recruit and train volunteers to assist in the Refuge Visitor 

Center and provide introductory information to visitors 

Rationale

Maui residents have a fairly strong volunteer ethic and they are willing to help out if they know what 

is available to them. The Refuge’s volunteer opportunities need to be advertised and the Refuge will 

continue to participate in community events. With additional staffing, we will put more effort into 

recruiting volunteers for all programs (biological, habitat, visitor services, EE, and interpretation). 

The value of the coastal dunes to sea turtles and native plants is interpreted in boardwalk panels. The 

coastal dune restoration project involves Refuge volunteers and the community and helps to instill a 

sense of stewardship of the natural resources. Volunteers will be recruited and trained to operate the 

Keālia Pond Visitor Center and provide a point of contact to visitors at the Keālia Coastal 

Boardwalk. Establishment of a Friends group is a high priority for operating the visitor center and 

assistance with other programs on- and off-Refuge (sea turtle monitoring program or Dawn Patrol). 

Volunteers assisting with propagation and planting native plants will also be working in the 

greenhouse to propagate plants specifically for restoring habitat on Molokini. Although they will not 

be able to travel to the islet due to safety concerns, their contributions will be essential.
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 2. Alternatives, Goals, Objectives, and Strategies 2-39

2.5.7 GOAL 7. Provide students and teachers high quality hands-on EE 

programs that foster a connection with nature and the Refuge. 

Objective 7.1: Provide a high-quality EE program. 

Expand EE programs that connect children with nature and focus on the functions of wetlands and 

coastal ecosystems as part of watersheds. Quality curriculum includes: 

 Supports national and State Department of Education (DOE) standards; 

 Provides interdisciplinary opportunities that link natural resources through all subject areas; 

 Incorporates the Refuge System mission and individual Refuge purposes; 

 Involves the local community, volunteers, Friends group, and partners; 

 Involves hands-on learning opportunities and stewardship components; 

 Incorporates current conservation issues and concerns; and 

 Located both on- and off-Refuge. 

Strategies Applied to Achieve Objectives Alt A Alt B Alt C 

Annual number of EE programs 1-2 2-5 5-12

Issue SUPs to EE organizations to conduct programs on the Refuge   

Participate in teachers’ workshops   

Design/produce a pamphlet for boardwalk interpretive panels   

Develop site-specific curriculum materials for educators  

Strategies Applied to Achieve Objectives Alt A Alt B Alt C 

Provide formal learning experiences on the Refuge that support 

teachers’ curricula and DOE requirements 

 

Establish and train volunteer docents to greet students and oversee 

EE programs at the Keālia Coastal Boardwalk 



As part of the VSP, develop a more formalized EE program 

including curriculum, operations and evaluation techniques. 



Rationale 

Keālia Pond NWR is one of three wetlands on Maui that provides hands-on opportunities for school 

children. Our proximity to schools and year-round access provides teachers, students, and other local 

education organizations an opportunity to study natural resource management and conservation 

issues in an outdoor setting. Hands-on experiences and exposure to wildlife career opportunities can 

help direct students into natural resource disciplines. Teachers may not have the time and resources 

to compile pre- and post-visit materials; therefore, the Refuge can provide packets geared for 

different age groups for teachers to incorporate the visit into their curriculum. 

We rely on partner organizations to provide formal EE opportunities to students by establishing 

SUPs each year. Organizations include Hawai‘i Nature Center (conducting the wetland curriculum 

at the Refuge for 14 years), Maui Digital Bus (for 8 years), and individual teachers’ on their own. 

The new visitor services manager will be responsible for the EE program. 

Refuge-specific EE programs should be developed for school groups. Development of all programs 

will include pre- and post-visit materials for the teachers use. Teachers’ workshops will be held 

annually to ensure DOE requirements are met. Volunteers would be recruited and trained to assist 

with the program. All EE programs will have a stewardship component where students would 

participate in a wetland restoration project. Currently, this includes hand removal of invasive plants 

and outplanting native plants. Cultural resources, which provide data and places to educate about 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

2-40 Chapter 2. Alternatives, Goals, Objectives, and Strategies 

changes in wildlife populations and the landscapes they inhabit, as well as cultural knowledge about 

the traditional uses of plants and animals, should be incorporated into EE curricula and programs. 

Programs for high school students included Baldwin High School (built nest platforms), Kīhei 

Charter School (comparison of invasive plant controls), Lahainaluna High School (GIS), and Maui 

High School (GIS). Hands-on opportunities give students a chance to experience a biologist careerfield and also provide another tool for investigating alternative management methods for the Refuge. 

Other opportunities will likely become apparent as the Refuge implements programs and receives 

feedback from teachers and educators. 

Objective 7.2: Provide high-quality internship opportunities. 

Expand the Refuge internship program for Maui’s students. Interns will be introduced to natural 

resource careers through hands-on work with, and training by, natural resource professionals to help 

develop a new generation of enthused and effective conservationists and ecologists. 

Strategies Applied to Achieve Objectives Alt A Alt B Alt C 

Annual number of internships 1-2 3-4 4-5

Collaborate with the University of Hawai‘i campuses (Maui, 

Hilo) to host interns receiving credit hours 

  

Develop an internship program for Kamehameha Schools in 

their Natural Resources Academy 

  

Host Americorps and Youth Conservation Corps students   

Strategies Applied to Achieve Objectives Alt A Alt B Alt C 

Develop an internship program for public schools on Maui 

Host Mainland and international interns 

Explore the potential for housing on- or off-site 

Rationale 

The DOI is engaging young people across the country in conservation and energy efficiency projects 

on America’s public lands, to inspire and provide career pathways in natural resource occupations 

and related sciences, and to become better educated about the Nation’s ecosystems. Establishing an 

internship with Kamehameha Schools will benefit the students but also recruit Native Hawaiian 

students into environmental conservation fields. Interns play a vital role in helping the Refuge 

System in preserving a national network of lands and waters for the conservation and management of 

the fish, wildlife, and plants of the United States for the benefit of present and future generations. 

Most internships last between 12-20 weeks and offer opportunities to: 

 Gain valuable hands-on natural resource management experience; 

 Put your education to work; 

 Earn college credit; and 

 Gain a working knowledge of the Service useful for future career decisions. 

The Youth Conservation Corps (YCC) is a program for young adults who are between the ages of 

15-18; where projects are conducted for 8-10 weeks during the summer. Environmental awareness is 

an integral aspect of the YCC program, with projects embracing both work and environmental 

learning goals. The participants spend most of their time in the outdoors. All participants are 

expected to gain an understanding and appreciation of the nation’s environment and heritage equal to 

1 full academic year of study.
 Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 3. Physical Environment 3-1 

 

Chapter 3. Physical Environment

3.1 Refuge Introduction 

Keālia Pond is adjacent to Mā‘alaea Bay along the south-central part of the Island of Maui, Hawai‘i. 

The Refuge is separated from the bay on the south side by a narrow band of coastal dunes. Located 

within the isthmus bounded between the West Maui Mountains and Haleakalā, the Refuge is exposed 

to the regularly occurring tradewinds that come from the northeast and subject to the less frequent 

Kona (southerly) winds. Although the isthmus is less than 12 miles in length (north-south), the 

Refuge lies within a dry area compared to the wetter north shore. 

The Refuge wetlands were formed by the combined natural action of the wind, waves, and erosion 

and act as a sump within the floodplain for the Waikapū watershed that drains approximately 56 

square miles. This results in unique climatological and hydrological conditions that direct 

management capabilities. 

Molokini Islet is an eroded remnant of a tuff cone, arising from Haleakalā’s southwest rift in the 

Alalākeiki Channel about 3 miles west of Pu‘u Ola‘i on Maui’s south shore. The islet reaches a 

maximum elevation of 165 feet. The outer sea cliffs are pockmarked with weathered holes and 

Keālia Pond and West Maui Mountains © Tony Temple
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

3-2 Chapter 3. Physical Environment 

shelves, and an average slope of about 73 degrees. The inner walls are not as steep with a 32 degree 

slope. The inner walls terminate in vertical sea cliffs above a wave cut terrace at the water’s edge. 

The ridgeline distance between the islet’s 2 northern points is nearly 3,200 linear feet and the total 

area is about 23 acres. Submerged remnants of the cone extend seaward in an arc from the northwest 

point. 

3.2 Climate 

Located 2,400 miles southwest of the nearest continental landmass, the Hawaiian Islands are the 

most isolated archipelago in the world. The climate of Hawai‘i is generally constant throughout the 

year, with only minor periods of diurnal and seasonal variability. During the summer season, 

temperatures are slightly warmer, conditions are drier, and trade winds originate from the northeast. 

The winter season is characterized by cooler temperatures, higher precipitation, and gustier winds. 

Native Hawaiians recognized only 2 seasons of 6-months each: a warm season with drier weather 

and more reliable trade winds and a cooler wetter season with more storms and fewer trade winds. 

Modern analysis of climate records indicates the soundness of the Hawaiian system of seasons. The 

wet season is now considered to extend 7 months October-April and the dry season May-September. 

During the wet season, there may be two or as many as seven major storm events a year. Such 

storms typically bring heavy rains and large stream runoff into the pond and are often accompanied 

by strong Kona winds that blow from the south. Rainfall and stream runoff are rare during the MaySeptember dry season. 

One of the most noticeable features in Hawai‘i’s climate is the persistent trade wind flow. The north 

Pacific anticyclone (high pressure area) moves south to north seasonally with the sun, and reaches its 

northern-most position at summer half-year. This position brings the center of the trade winds across 

Hawai‘i during May-September. Trade winds are prevalent 80-95 percent of the time during this 

period. During October-April, the Pacific High moves south of the islands. Trade winds still blow 

across the island much of this period, but with less frequency (50-80 percent of the time in terms of 

monthly averages). 

Topography has a profound effect on wind on Maui. The funneling effect of Haleakalā and the West 

Maui Mountains tends to accelerate the normal tradewinds through the isthmus of the island. Keālia 

Pond, being located at the south end of the isthmus, is exceptionally windy, even for Hawai‘i, 

because of this effect. Data on wind speed and direction at Keālia Pond have been collected 

regularly since 2002. The average monthly wind speed is shown in Figure 3.1. Wind speeds are 

greatest in the summer months with July being the windiest month at the pond. Wind is generally 

less consistent during the winter months, although there are some very windy days associated with 

Kona winds that blow from the south instead of the north. The timing and seasonality of winds at 

Keālia Pond have some important physical and biological implications that will be discussed later. 

 
 Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 3. Physical Environment 3-3 

Figure 3.1. Average monthly wind speeds at Keālia Pond NWR, 2002-2006.

The Hawaiian Islands are broadly separated into two physiographic zones: windward and leeward, 

depending on the exposure to tradewinds and associated precipitation. Keālia Pond is located in the 

leeward zone of the island. As a result of this and the rain shadow effect from Haleakalā, the area 

around Keālia Pond is arid. Tributary streams to Keālia Pond drain 56-square miles of the West 

Maui Mountains. Rainfall data at the Refuge has only been collected since 2000. However, there are 

four National Weather Service cooperative weather stations near the Refuge with rainfall data from 

1950 to the present. Of the four stations, monthly rainfall at Kīhei, HI (station 514489) appears most 

similar to that measured at the Refuge, based on the period of overlapping records. 

Approximately 92 percent of the total annual rainfall at the Kīhei station falls October-April. The 

period May-September is typically quite dry and windy in the area. Annual precipitation at the Kīhei 

station for the period 1950-2010 has averaged about 13 in/yr but has varied greatly from a minimum 

of 3 in/yr to a maximum of 30 in/yr. There has been slightly less precipitation and greater variability 

during the last half of the 57-year record. Figure 3.2 shows the average monthly precipitation at 

Kīhei from 1950-2010. 

Generally, there is little variation in monthly temperatures through the year. Temperatures are 

usually warm and pleasant year-round with average January daytime temperatures around 81 degrees 

F and July/August averaging about 88 degrees F. Evening lows in January average about 63 degrees 

F with the summer evening lows averaging 69 degrees F. While there is very little variation in annual 

temperature there appears to be an increase in the late 1970s which may correspond to the widelyrecognized shift in the Pacific Decadal Oscillation (PDO) from negative to positive phase in 1977. 

 

Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep

Wind Speed (mph)

0

3

6

9

12
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

3-4 Chapter 3. Physical Environment 

Figure 3.2. Annual cycle of average monthly precipitation (top) and total annual precipitation 

with 5-year moving average (bottom) at Kīhei, HI, 1950-2008. 

3.2.1 Global Climate Changes and Projections 

Global climate change is supported by a continuously growing body of unequivocal scientific 

evidence. The Intergovernmental Panel on Climate Change (IPCC) is a scientific intergovernmental 

body organized by the World Meteorological Organization and the United Nations Environment 

Programme in order to assess the causes, impacts, and response strategies to changes in climatic 

conditions. According to the Fourth Assessment Report by the IPCC, global temperatures on the 

Earth’s surface have increased by 1.33°F over the last 100 years. This warming trend has accelerated 

within the last 50 years, increasing by 0.23°F each decade. Global ocean temperatures to a depth of 

almost 2,300-feet have also increased, rising by 0.18°F between 1961 and 2003 (Solomon et al. 

2007). 

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

U.S. Government agency Overseas Private Investment Corporation (OPIC) suggests that a further 

increase in greenhouse gas (GHG) emissions could double atmospheric concentrations of CO2 by 

2060 and subsequently increase temperatures by as much as 2-6.5°F over the next century. Recent 

model experiments by the IPCC show that if GHGs and other emissions remain at 2000 levels, a 

further global average temperature warming of about 0.18°F per decade is expected. Sea level rise 

Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep

Precipitation (in)

0

1

2

3

4

1950 1960 1970 1980 1990 2000 2010

0

10

20

30

40
 Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 3. Physical Environment 3-5 

(SLR) is expected to accelerate by two to five times the current rates due to both ocean thermal 

expansion and the melting of glaciers and polar ice caps. Recent modeling projects sea level to rise 

0.59-1.93-feet by the end of the 21st century. These changes may lead to more severe weather, shifts 

in ocean circulation (currents, upwelling), as well as adverse impacts to economies and human 

health. The extent and ultimate impact these changes will have on Earth’s environment remains 

under considerable debate (OPIC 2000, Buddemeier et al. 2004, Solomon et al. 2007, IPCC 2007). 

3.2.2 Climate Change in Hawai‘i 

Climate change impacts expected for Hawai‘i are warmer temperatures (air and ocean), more severe 

droughts and floods, and a rise in sea levels. Giambelluca et al. (2008) reported that air temperatures 

in Hawaii have increased at a rate of 0.3 degrees F/decade since 1975, which is comparable to the 

rate of increase in global temperatures. Temperature observations at the Mauna Loa Observatory in 

Hawai‘i from 1977-2006 indicate a warming trend of 0.4 degrees F/decade. Rainfall intensity has 

increased 12 percent in Hawai‘i between 1958-2006 but total rainfall has decreased about 15 percent 

over the last 20 years. These changes have and will continue to affect biologic and water resources 

on Maui and the other islands (Mimura et al. 2007, Oki 2004, Chu and Chen 2005, Turcotte and 

Malamud 2009, Fletcher 2010). 

The Service is supporting the development of regional Landscape Conservation Cooperatives that 

will integrate local climate models with models of climate-change responses by species, habitats, and 

ecosystems. The regional version of these Landscape Conservation Cooperatives is the Pacific 

Islands Climate Change Cooperative (PICCC), headquartered in Honolulu, Hawai‘i, but working 

across the Pacific. The PICCC was established in 2010 to assist those who manage native species, 

island ecosystems, and key cultural resources in adapting their management to climate change for the 

continuing benefit of the people of the Pacific Islands. The PICCC steering committee consists of 

more than 25 Federal, State, private, indigenous, and non-governmental conservation organizations 

and academic institutions, forming a cooperative partnership that determines the overall 

organizational vision, mission, and goals. 

 

Similar to the rest of the world, temperatures in Hawai‘i are rising. The EPA has estimated that the 

average surface temperature in Honolulu, Hawai‘i has increased by 4.4 degrees F over the last 

century. In particular, nighttime temperatures are notably warmer, increasing by about 0.5 degrees F 

per decade over the past 30 years. Recent studies have shown that this rising average night 

temperature is greater at high elevation sites than lower areas. Sea surface temperature near the 

islands has been increasing recently, showing a 0.72 degrees F rise from 1957-1987. Sea level around 

the Hawaiian Islands is rising by 6-14 inches per century. Over the last 90 years, precipitation has 

also decreased approximately 20 percent (EPA 1998, Arakawa 2008, Giambelluca 2008). 

Global and regional predictive climate simulations may not capture unique and important features of 

the Hawaiian climate. Existing large-scale models show large variability and uncertainty for the 

Hawaiian Islands; thus, applying these models to predict local conditions must be done with caution 

until more fine scaled models are developed. Models from the IPCC and United Kingdom Hadley 

Centre’s climate model suggested that by 2100 annual temperatures in Hawai‘i could increase by 3 

degrees F, with a slightly higher increase in fall. Other estimates predict a 5-9 degrees F rise by the 

end of the 21st century. Future changes in precipitation are uncertain, dependent largely on shifts in 

El Niño/La Niña events. Some predictions forecast an additional rise of 17-25 inches by 2100, while 

others suggested decreased precipitation. The trend in precipitation at the Refuge, shown in Figure 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

3-6 Chapter 3. Physical Environment 

3.3, has been decreasing since 1950. The temperatures, as shown in Figure 3.3, have been on a slight 

rise since 1950 (TenBruggencate 2007, Timm 2008).

Figure 3.3. Annual cycle of average monthly temperature (top) and mean annual temperature 

with 5-year moving average (bottom) at Kahului airport, HI, 1955 -2008. 

Long-term climate change may be increasing temperature and reducing precipitation, groundwater 

recharge, and streamflow in Hawai‘i for extended periods. Oki (2004) looked at long-term trends in 

streamflow from 1913-2004 for seven streams in Hawai‘i, including three on Maui, that 1) had data 

available, 2) were free of upstream regulation or diversion, and 3) represented a variety of physical 

and climatological characteristics. He reported statistically significant declines in baseflow in all 

seven streams but a statistically significant decline in total annual flow in only one of the streams. 

These baseflow declines are consistent with a long-term downward trend in rainfall observed over 

much of the State during that same period and may reflect a decrease in groundwater storage and 

recharge. However, the author states that detection of the trends was dependent on the period of 

record considered. He says that the downward trends may just reflect higher than average baseflows 

from 1913 to the 1940s, followed by a period with little or no trend in baseflows. 

1950 1960 1970 1980 1990 2000 2010

72

74

76

78

80

Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep

Temperature (F)

65

70

75

80

85
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Chapter 3. Physical Environment 3-7 

3.2.3 Sea Level Rise 

According to the IPCC, the oceans are now absorbing more than 80 percent of the heat added to the 

Earth’s climate system. Since 1961, this absorption has caused average global ocean temperatures to 

increase and seawater to expand. Thermal expansion of the sea is the primary cause of global sea 

level changes. Melting ice-sheets, ice caps, and alpine glaciers also influence ocean levels. 

Worldwide, sea level changes have historically occurred on a small scale; however, scientific 

evidence suggests that the current, accelerated rate of global change began between the mid-1800s 

and 1900s. Similarly, sea levels in the Pacific have regularly changed over the centuries due to 

variations in solar radiation. Since 1800, sea levels in the Pacific region have been rising. During the 

last century, these levels have risen about 6 inches and this is likely to rapidly increase in the next 

century (Noye and Grzechnik 2001, GAO 2007). 

 

Due to localized geographic and oceanographic variations, it is not possible to discuss SLR on a 

global scale. Near Pacific Island ecosystems, SLR is influenced by the rate and extent of global sea 

level rise, as well as changes in episodic events, such as the El Niño Southern Oscillation and stormrelated conditions. Topography and exposure to normal and storm swell produce localized 

differences. Furthermore, it is important to note that shoreline sea levels are historically and currently 

influenced by isostatic tectonic changes as the islands move with the Pacific Plate, which are not due 

to global changes in sea level. Thus, sea level change in the Pacific is highly variable due to geologic 

uplift (Michener et al. 1997, Carter et al 2001). 

Sea level rise is expected to exacerbate inundation, storm surge, erosion, and other coastal hazards. 

Currently, ocean waters only occasionally reach Keālia Pond during high tides with large waves. The 

frequency of these events will likely increase due to rising seas levels. It’s also likely that Keālia 

beach may be more prone to erosion which may threaten habitat and infrastructure in the area. 

In an effort to address the potential effects of sea level changes on national wildlife refuges, the 

Service contracted the application of the Sea Level Affects Marshes Model (SLAMM) 6 for several 

Pacific Region Refuges. This analysis is designed to assist in development of long-term management 

plans. The SLAMM model predictions for Keālia Pond NWR suggest that inland inundation within 

this Refuge will occur given SLR scenarios below 3 feet (eustatic). It is in the 3-feet scenario that 

rising waters begin to have an impact on the main part of the Refuge. The dry land (and beaches) 

between the main pond and the ocean, which acts as a natural impoundment against inundation, 

becomes heavily eroded in higher scenarios. 

There is little or no tidal influence within the Refuge, however, after 3-feet of SLR salt water is 

predicted to move beyond the road barrier. Within this SLAMM application, a connectivity algorithm 

was used to determine when floodwaters are predicted to penetrate beyond the road resulting in more 

frequent flooding and salinity changes within the refuge. Under the highest SLR scenarios, N. Kīhei 

Rd. is predicted to be regularly flooded and convert to ocean beach or open water. 

There is always uncertainty about how regularly flooded wetlands will respond to the signal of 

increased SLR. The most important effects of SLR at Keālia Pond and Mā‘alaea Flats are the gradual 

inundation and flooding of historic wetlands and dryland areas, as well as increases in the salinity of 

wetlands. Salinity alterations have the potential to shift aquatic plants and animal communities that 
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3-8 Chapter 3. Physical Environment 

do not tolerate high salinity. Higher sea levels may inundate these low-lying land areas, potentially 

helping Refuge personnel to reclaim/restore former wetland areas for endangered waterbirds. 

3.2.4 Ecological Responses to Climate Change 

Evidence suggests that recent climatic changes have affected a broad range of individual species and 

populations in both the marine and terrestrial environment. Organisms have responded by changes in 

phenology (timing of seasonal activities) and physiology; range and distribution; community 

composition and interaction; and ecosystem structure and dynamics. The reproductive physiology 

and population dynamics of amphibians and reptiles are highly influenced by environmental 

conditions such as temperature and humidity. For example, sea turtle sex is determined by the 

temperature of the nest environment; thus, higher temperatures could result in a higher female to 

male ratio. In addition, increases in atmospheric temperatures during seabird nesting seasons will 

also have an effect on seabirds and waterbirds (Duffy 1993, Walther et al. 2002, Baker et al. 2006). 

Changes in ocean temperature, circulation, and storm surge due to climate change will impact seabird 

breeding and foraging. The ENSO has been shown to cause seabirds to abandon habitats, nest sites, 

and foraging areas for colder/warmer waters. Studies have found that nesting success is reduced for 

some species during this climatic event. Oceanographic changes associated with ENSO may also 

increase or decrease food supply for seabirds and subsequently impact populations that forage 

offshore. Shifts in marine temperature, salinity, turbidity, currents, depth, and nutrients will have an 

impact on seabird and water bird prey composition and availability. Although these potential changes 

may impact seabirds throughout the Hawaiian Islands, contrary evidence suggests that seabirds may 

have coped with and evolved around climatic changes in the past (Duffy 1993). 

Warming has also caused species to shift toward the poles or higher altitudes and changes in climatic 

conditions can alter community composition. For example, increases in nitrogen availability can 

favor those plant species that respond to nitrogen rises. Similarly, increases in CO2 levels can impact 

plant photosynthetic rates, decrease nutrient levels, and lower herbivore weights. Although there is 

uncertainty regarding these trajectories, it is probable that there will be ecological consequences 

(Vitousek 1994, Walther et al. 2002, Ehleringer et al. 2002). 

Climate change has the potential to influence two important ecological issues in the State of Hawai‘i: 

endangered species and pest species. The majority of U.S. endangered species are found in the State 

of Hawai‘i. Species declines have resulted from habitat loss, introduced diseases, and impacts from 

pest species. Changes in climate will add an additional threat to the survival of these species. For 

example, warmer night temperatures can increase the rate of respiration for native vegetation, 

resulting in greater competition from pest plants. Furthermore, climate change may enhance existing 

pest species issues because alterations in the environment may increase the dispersal ability of flora 

or fauna. Species response to climate change will depend on the life history, distribution, dispersal 

ability, and reproduction requirements of the species (DBEDT and DOH 1998, Middleton 2006, 

Giambelluca 2008). 
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3.2.5 Climate Change at at Keālia Pond 

Most of the anticipated climate change impacts at Keālia Pond involve water supply and water 

quality. Tributary streams that flow into Keālia Pond originate in the West Maui Mountains, which is 

one of the wettest places in the world. Hydrologic conditions at Keālia Pond are largely dependent on 

streamflow inputs, which can be highly variable from year to year and are affected by climatic 

conditions and upstream regulation. Both short-term interannual climate variability and long-term 

decadal variability affect streamflows on Maui and the other islands. Many of the droughts in 

Hawai‘i are related to El Niño events, which are associated with drier than normal winters. The PDO 

also influences Hawaiian climate. The pattern of ocean-atmosphere variability associated with ENSO 

phenomenon occurs on a relatively short time scale of 1 to several years while the PDO is a longer 

term phenomenon occurring over 1 to several decades. Rainfall and streamflow tends to be low in 

winter during El Niño periods and high during La Niňa periods, especially during positive (warm) 

phases of the PDO. Temperature may be affected by PDO phases too. A number of studies suggest 

that climate change could be a major factor in accentuating the current climate regimes and the 

changes from normal that come with ENSO events (Mimura et al. 2007, Oki 2004)). 

It is difficult to assess the relative threat of long-term changes in rainfall and runoff to Keālia Pond. 

Certainly declines in rainfall and runoff, including baseflow, would affect the water supply for the 

pond. Warmer air temperatures may mean warmer water temperatures, decreased dissolved oxygen, 

and greater evaporation. Nuisance issues of blowing dust and fish kills may also be expected to be 

more common. Presently, the water level record at Keālia Pond is not long enough to assess whether 

or not the frequency of dry conditions has already increased in response to warmer temperatures, 

increasing evaporation, and decreasing precipitation. However, any gradual, long-term changes in 

rainfall and stream inflow may be overshadowed by more immediate and direct changes in upstream 

regulation and diversion and land management practices. As will be discussed below, such changes 

have the potential to greatly modify pond hydrology and ecology. 

More severe flooding would also affect Keālia Pond in a number of ways. They may increase the 

frequency or severity of disturbance in the pond and may also increase sediment loads reaching the 

pond, which could affect water quality and pond bathymetry. More severe flooding would also 

underscore the hydrologic function of Keālia Pond with respect to ameliorating flooding and run-off 

to the ocean. The pond and surrounding area act as a buffer, capturing flood waters and holding them 

before they move into the ocean (either as surface flow or subsurface seepage). The wetland protects 

the adjacent beach and offshore coral reef ecosystem from deleterious effects of erosion, 

sedimentation, and eutrophication associated with flood waters. 

By the end of the 21st century, sea levels are expected to rise 7.6-23.2 inches, relative to 1980-1999 

levels. Sea level rise is expected to exacerbate inundation, storm surge, erosion, and other coastal 

hazards. Currently, ocean waters only occasionally reach Keālia Pond during high tides with large 

waves. The frequency of these events will likely increase due to rising seas levels. It is also likely 

that Keālia beach may be more prone to erosion due to rising sea levels and higher storm surges. This 

may threaten habitat and infrastructure in the area (Mimura et al. 2007). 
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3.3 Geology and Soils 

The Hawaiian Islands were formed by a series of volcanic eruptions that occurred at hotspots beneath 

the Earth’s crust. As the tectonic plate slowly drifted, magma welled up from fixed spots creating a 

linear chain of islands. Iron-rich, quartz-poor rock flowed out of thousands of vents as highly fluid 

lava. 

3.3.1 Keālia Pond 

The Island of Maui formed from two shield volcanoes that were close enough that their lava flows 

overlapped, forming an isthmus between them. The oldest volcano, now forming the West Maui 

Mountains, is about 5,000 ft high. The younger volcano, Haleakalā, on the east side of the island is 

over 10,000 ft high. The isthmus that separates the two volcanic masses is formed from sandy 

erosional deposits and is the prominent topographic feature for which the island is known: “the 

Valley Isle.” 

A general soil survey for Maui County, including Keālia Pond, was completed by the Natural 

Resources Conservation Service (NRCS) in 1972. Soils at Keālia are all classified as Keālia silt 

loam. This soil series is found along coastal flats throughout the island and is associated with nearly 

level, poorly drained soils with high salt content. Ponding occurs in low areas after heavy rains, and 

salts accumulate on the surface with drying and evaporation. A representative soil profile consists of 

a dark reddish-brown silt loam about 3 inches thick with stratified layers of silt loam, loam, and fine 

sandy loam below this. A brackish water table occurs at a depth of 12-40 inches. The soil has a 

high concentration of salts and is moderately alkaline. It is highly erosive when dry and the surface 

becomes loose and fluffy. 

Soils profiles described at several cores collected at Keālia Pond were generally silt loams and silty 

clays intermixed with layers of coarser sandy loams and fine sands at depth. The water table in the 

cores was consistently encountered at the depth of the sand layer or in the soil horizon just above it. 

This suggests that coarser textured sand layers may be acting as conduits or permeable horizons for 

groundwater movement into, out of, or underneath and around the pond. Reportedly there is a 

hardpan underlying much of the bottom of the pond itself, which probably acts to seal the pond 

bottom and minimize groundwater/surface water exchange (Smith and Medeiros 1952, Nakai and 

Mayer 2001). 

At two sites near the historic mouth of Waikapū Stream, the presence of the sands and rounded 

basalts indicated that at one time the stream channel flowed with enough energy to carry and deposit 

such material near the pond. Presently, the stream lacks a defined channel near the pond and does 

not appear to transport and deposit such material anymore. In cores located away from the Waikapū

Stream channel, the sand layer still exists at depth but the sands are finer textured and there are no 

rounded basalts. The more permeable soils near the mouth of Waikapū Stream result in water levels 

that are much flashier and more variable than elsewhere, based on water level data from piezometers 

installed near the pond. There is a much larger range of water levels here as compared to elsewhere 

around the pond. 
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The presence of permeable sand layers and/or a hardpan has implications for management proposals 

to excavate the pond or construct additional impoundments. If dredging or excavation is deep 

enough to intersect the sand layers, this may facilitate the flow of subsurface water into or out of the 

pond or impoundment, depending on local head gradients. Groundwater in some of the shallow 

wells around the Refuge, especially on the north shore and to the southeast, is very saline (as much as 

70 parts per thousand (ppt) or more). Intersecting a deeper, permeable layer with high salinity 

groundwater during dredging may cause saline groundwater to flow into the pond and may alter pond 

ecology. Additionally, the presence of a hardpan layer underlying the pond would be important to 

consider as well. It is not known how thick this layer is or what is below this layer but removing this 

impediment to drainage and groundwater movement would undoubtedly affect pond hydrology and 

water quality as well. 

Chemical analysis of sediments in 2001 in the pond found high salinity. The average conductivity of 

1:1 soils to distilled water mix was approximately 4 ppt salinity. The high salinity of the sediments 

was apparently the reason HC&S abandoned plans to drain the pond and grow sugar cane in the early 

part of the 20th century. The high salinity of the sediments may also be part of the reason for a lack 

of rooted vegetation in the pond. The only substantial area of emergent aquatic vegetation in the pond 

is the area receiving freshwater from the wells. Sediments upgradient in the stream channels are not 

saline, suggesting that salts are accumulating in the pond and not being transported to it (Smith and 

Medeiros 1952). 

All the soils and sediments are very high in phosphorus (P) (total, extractable, and water soluble) and 

ammonia-nitrogen (N) but fairly low in nitrate-N. Phosphorus is commonly the nutrient limiting 

primary productivity in aquatic systems but Keālia seems to be naturally rich. 

3.3.2 Molokini 

The tiny, crescent-shaped islet of Molokini lies 3 miles offshore of Maui. Molokini is a volcanic cone 

that rises about 500 ft from the submarine flank of Haleakalā to a summit only 162 ft above sea level. 

The cone is capped by a crater 1,770 ft in diameter, although the northern rim is below sea level and 

the crater is flooded by the sea. It was active about 230,000 years according to an age measured from 

lava fragments contained in the cone. Molokini is completely exposed to tradewinds through the 

Maui isthmus on its north side and easterly winds wrapping around Maui to hit its south side. Wave 

action is continuously eroding the islet as evident by the undercutting along the sides (USGS 2008). 

Hundreds of ancient cinder cones can be found all around Maui, but Molokini is unique because it is 

one of the few that rose all the way from the deep ocean floor and erupted above the water. Many of 

these never break the surface of the water and just erupt below the surface. When the islands were 

forming, molten lava flowed beneath the surface of the ocean through porous tubes. These tubes also 

trapped water within their rocky structure. When magma erupts explosively in shallow water, the 

liquid water heats, expands rapidly, and changes to steam, adding to the eruptive force. Rock and 

cinder were spewed into the sky and formed a crescent shape as they fell (USGS 2008). 

Shallow marine eruptions have two consequences for the appearance of the resulting cone. The first 

is grain size, because the ripping power of these marine eruptions leads to finer-grained deposits than 

in cinder cones onshore. The second is the abundance of volcanic glass, because the lava fragments 

are quickly cooled by water before crystals can form. Glass is a geologically unstable material. It 
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3-12 Chapter 3. Physical Environment 

alters rapidly to brownish-yellow clays, giving Molokini its earthy yellow color. In contrast, cinders 

erupted on land are reddish and black. The Molokini deposits are basanite, a type of basalt with fairly 

low amounts of silicon and high concentrations of sodium and potassium (USGS 2008). 

3.4 Hydrology 

The hydrologic processes that occur in the Hawaiian Islands are unique compared to continental 

landmasses or temperate zones. Drainage basins are typically small and streams are characterized by 

steep longitudinal profiles and numerous waterfalls. Due to its location, Keālia Pond has historically 

served as a settling/deflation basin for a 56-square mile watershed extending to the West Maui 

Mountains. There are three major streams that are tributary to the wetland: Pōhākea Stream, 

Pale‘a‘ahu Stream, and Waikapū Stream. All three streams are unpredictable and intermittent, some 

of which is due to diversions for agriculture. Wilcox (1996) reports that most of Hawai‘i’s streams 

are flashy, with flow rates that rise and fall rapidly in response to precipitation. Several other 

streams occasionally flow into the wetland from the west side of Haleakalā during very high rainfall 

events. Historically, these streams may have flowed into the wetland more frequently. 

Hydrologic conditions at Keālia Pond vary considerably seasonally and annually. During the wet 

season, the pond usually maintains moderate to high water levels due to increased precipitation and 

streamflow. The maximum pond depth is about 3-4 ft. As summer progresses, precipitation 

decreases, less stream water flows into the pond, and the water levels recede. Some years, inflows 

are sufficiently high to maintain pond levels throughout the summer. Most years, water levels begin 

to recede by April or May, resulting in very low water levels or even dry conditions in the pond by 

late summer or early fall. 

3.4.1 Annual Hydrologic Cycle 

The information presented next is based on pond water level data collected at Keālia Pond from 

1996-2006. Since June 2000, pond levels have been recorded hourly with a datalogger. Figures 3.4, 

3.5, and 3.6 show the pond levels and monthly precipitation for water years 1996-2007. The 

relationship between precipitation and water levels can be observed in the figures, with wetter years 

and wetter times of the year resulting in higher water levels. 

In most years, Keālia Pond fills quite abruptly (within days) due to a combination of rainfall and runoff following the first major storm in the fall or winter. Usually, this occurs in October or November, 

although it has happened later, as in 2000 and 2006. Rainfall directly on the pond is a fairly minor 

component of the total inflow into the pond. The majority of inflow is from runoff and streamflow. 

Inflow reaches the pond in three forms: as direct streamflow from any of three major tributaries to 

the pond; as runoff and diffuse surface flow from the surrounding lands; and as subsurface flow 

(groundwater seepage). 

Of the three main streams flowing to the pond, Waikapū Stream is the major contributor of inflow 

during the wet season. Although this stream is dry much of the time, the volume of water is 

considerable when it is flowing. Peak flow measurements were collected annually from 1963-1997 

at USGS 16650500 Waikapū Stream, located just upstream of the Refuge at Lower Mā‘alaea Rd. 
 Keālia Pond National Wildlife Refuge 

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The peak flows averaged 620 cfs and ranged from 104-1,130 cfs. Flows greater than 1,000 cfs are 

not uncommon in the record. Weekly estimates of flow were collected at this same site by Refuge 

staff 2001-2006. The maximum estimated flow recorded was 450 cfs and the site was dry about 80 

percent of the weekly visits. Historically, Waikapū Stream was believed to be perennial through its 

entire reach but the stream was fully diverted of all but peak flows many years ago for the purpose of 

cane irrigation. There is presently a reservoir upstream of the Refuge on Waikapū Stream that may 

affect inflows to the pond. Within the past five years, water rights issues have come to the forefront 

between environmental groups, agricultural companies, and user groups that include the Waikapū

Stream. However, to date, the State's decision to return water to some of the West Maui streams has 

not included the Waikapū Stream (Maciolek 1971). 

The other two streams, Pōhākea and Pale‘a‘ahu, make up a smaller fraction of the streamflow to the 

pond. Weekly flow estimates of these two streams were collected by Refuge staff 2001-2006 as 

well. These two streams are still intermittent but flow more consistently than Waikapū Stream. 

Pōhākea Stream was dry an average of 50 percent and Pale‘a‘ahu Stream was dry an average of 20 

percent of the weekly visits. The maximum estimated flow was 94 cfs in Pōhākea Stream and 25 cfs 

in Pale‘a‘ahu Stream. Flows in Pōhākea Stream have been greatly reduced since 2004, based on 

Refuge staff observations. From 2001-2004, Pōhākea Stream was observed to be dry 23 percent of 

the weekly visits to the stream. In 2005 and 2006, the stream was dry 92 percent of the weekly visits. 

The decrease is likely due to some upstream change in water or land management. Pōhākea Stream 

is not a major contributor of inflow to the pond. The major effect of this change is that the area 

around the outlet channel of this tributary has become slightly drier. 

Groundwater levels are quite dynamic and generally follow the same seasonal patterns as surface 

water levels in the pond. There is large temporal and spatial variability in water table levels and 

groundwater salinity. However, the groundwater system appears to be only weakly connected to the 

surface water system and groundwater seepage to the pond is a minor component of total inflow. 

Groundwater does not seem to influence the pond in terms of quantity or quality, although 

groundwater storage adjacent to the pond may buffer the pond water levels to some extent. 

During the wet season, inflows from rainfall and streamflow usually exceed outflows, maintaining 

high pond water levels through this season. As precipitation and runoff decrease in the late spring 

and summer, pond levels begin a slow, steady decline. This decline usually begins in April or May 

and continues unabated throughout the dry season until the fall rains begin. Water is lost from the 

pond through three processes: 1) surface flows to the ocean; 2) groundwater seepage losses; and 3) 

evapotranspiration losses. Based on the physical constraints to surface outflow discussed below and 

the consistency of salinity measurements as the pond recedes (discussed later), the primary water loss 

from the pond appears to be through evaporation. 
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3-14 Chapter 3. Physical Environment 

Figure 3.4. Water level depths and monthly precipitation at Keālia Pond NWR, water years 

(WY) 1996-1999.

1

2

3

4

3

6

9

12

blw gage

3

6

9

12

Water Level Depth (ft)

1

2

3

4

1

2

3

4

3

6

9

12

Outlet breached by refuge on 2/2/98

Fish kill

Well pump

turned on

Date of 

fish kill

unknown

WY 1996

WY 1997

WY 1998

Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep 

1

2

3

4

3

6

9

12

Monthly Precipitation

Water Levels

no data

Well pump

turned on

Fish kill

blw gage

WY 1999

Kīhei Precipitation (in) 
 Keālia Pond National Wildlife Refuge 

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Chapter 3. Physical Environment 3-15 

Figure 3.5. Water level depths and monthly precipitation at Keālia Pond NWR, 2000-2003.

1

2

3

4

3

6

9

12

1

2

3

4

3

6

9

12

Well pump on 

through summer

Well pumpon 

through summer

Fish

kill

Water Level Depth (ft)

1

2

3

4

Refuge Precipitation (in)

3

6

9

12

Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep 

1

2

3

4

3

6

9

12

Monthly Precipitation

Water Levels

Fish

kill

Well pump 

turned on

WY 2000

WY 2001

WY 2002

WY 2003
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Figure 3.6. Water level depths and monthly precipitation at Keālia Pond NWR, 2004-2007.

1

2

3

4

3

6

9

12

Well pump

turned on

Water Level Depth (ft)

1

2

3

4

3

6

9

12

Well pump 

turned on

Fish

kill

1

2

3

4

Refuge Precipitation (in)

3

6

9

12

Well pump 

on Fish

kill

Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep 

1

2

3

4

3

6

9

12

Monthly Precipitation

Water Levels

WY 2004

WY 2005

WY 2006

WY 2007
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Surface outflows to the ocean occur only occasionally in the winter at high pond levels (greater than 

4 ft MLLW approximately). The outlet channel from the bridge to the ocean is usually blocked by a 

sand plug formed naturally by ocean currents and tidal action. This sand plug and the beach berm 

separating the pond from the ocean cause water to pond up. Large rain events will raise the pond 

level enough to breach the sand plug temporarily, allowing surface outflow to the ocean and resulting 

in a rapid drop in pond levels. The sand plug typically rebuilds within several days. Although the 

water that outflows to the ocean contains some suspended sediment and organic matter, Maciolek 

(1971) believed that, at the time of the report, this turbidity was not severe enough to harm the 

Mā‘alaea coral reef community living at or to the west of the discharge point. 

There appears to be a small amount of subsurface seepage through the sand beach berm and plug 

from the pond to the ocean. Water can be observed to be flowing out under the bridge on N. Kīhei 

Rd. even when the sand plug is in place and there is no surface outflow to the ocean. This indicates 

the existence of subsurface seepage through the beach berm separating the pond and the ocean. The 

sand substrate of the beach berm is probably more permeable than the silts and clays underlying the 

remainder of the pond. The subsurface seepage outflow is estimated to be as high as 2 cfs or 4 acrefeet/day, depending on the pond elevation. Subsurface seepage losses will be head-dependent, 

meaning the higher the pond level, the greater the subsurface seepage outflow. 

The elevation of the bottom of the box culvert under the bridge is 2.54 ft MLLW. As the water level 

recedes below this elevation, the box culvert blocks any outflow under the bridge, isolating the pond 

from the area of seepage outflow. Seepage losses in other areas of the pond are very small and, it 

appears that pond outflows at water surface elevations less than about 2.5 ft MLLW are solely 

through evaporation. The pond essentially acts as a closed basin as pond levels recede below the 

elevation of the box culvert at the bridge. This has important chemical and biological implications 

since evaporation concentrates salts, nutrients, and other solutes, as will be discussed later. 

One of the characteristics of evaporative losses at pond levels less than 2.5 MLLW is that they are 

quite predictable. The rate of evaporation varies seasonally but is consistent from year to year in the 

absence of any significant inflows. The dry season rate of decline, without any pumping of well 

water into the pond, has averaged 0.023 ft/day (0.65 ft/month), with a range from 0.020 ft/day, in 

2002, to 0.026 ft/day, in 1999 and 2008 (Table 3.1). Variability in the rate of decline during the dry 

season appears to be related mainly to fluctuations in evaporation rates and to occasional stream 

inflows during the period of decline. Pumping groundwater into the pond slows the rate of decline 

considerably. In 2000, the rate was 0.01 ft/day and in 2001, it was 0.008 ft/day. In both years, 

pumps were running fairly consistently throughout the spring and summer during the period of 

declining water levels. The rate of water level decline is slightly slower in the cooler wet season. In 

the absence of any groundwater pumping or inflows, it averages about 0.013 ft/day during the winter 

months and about 0.18 ft/day during spring/fall months, based on data from 2007 and 2008. 

 
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Table 3.1. Rates of Water Level Decline for Periods with No Significant Inflow to Pond. 

Water Year Period with No 

Significant Inflow

Season Rate of Pond Level 

Decline (ft/day)

1998 2/24-5/21/98 Winter/Spring 0.021 

1999 6/23-8/26/99 Summer 0.026 

2000 4/17-9/5/00 Spring/Summer 0.010* 

2001 4/1-8/1/01 Spring/Summer 0.008* 

2002 8/24-10/11/02 Summer/Fall 0.020 

2003 5/17-7/24/03 Spring/Summer 0.023 

2004 9/5-24/04 Summer/Fall 0.022 

2005 5/26-8/1/05 Summer 0.022 

2006 7/4-9/5/06 Summer 0.026 

2007 2/3-3/12/07 Winter 0.017 

2008 2/22-4/30/08 Winter/Spring 0.018 

Summer 

Average

 

0.023 

* Wells were pumping continuously during the summer period during 2000 and 2001. These years were not 

included in the summer average rate of decline calculation. 

At the previous well capacity of approximately 700 gpm, groundwater pumping slowed the rate of 

decline and stabilized the pond elevation at about 1.00-1.30 ft MLLW (about 0.4-0.5 ft average pond 

depth) in the summer. This elevation range represents about 50-60 percent water coverage. Above 

this elevation, the evaporative losses are too great and the existing well capacity cannot meet the 

demand. 

There is about 2 feet of difference between winter maximum water levels and summer minimum 

water levels. Maximum water levels typically occur in winter months of February -April, with mean 

depths of about 3 feet. Even during the dry winter in 2006, the pond was full by April. June, July, 

and August levels have been quite variable, but are usually quite low in dry years. October and 

November have consistently been the months of minimum water elevations. Early fall storms are 

responsible for the higher elevations observed during October and November in some years. 

3.4.2 Water Quality of the Pond 

The water quality and algae information presented here is based on 5 years of monitoring at the pond 

from 2001-2006. In general, the pond is extremely productive and hypereutrophic, meaning 
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chlorophyll-a concentrations greater than 100 parts per billion (ppb) as classified by the 

Organization for Economic Cooperation and Development. Chlorophyll a had a median 

concentration of 125 ppb for the period but concentrations were greater than 1000 ppb on several 

occasions. Water temperatures, salinity, turbidity, macronutrient concentrations, chlorophyll- a 

concentrations, and algal biomass were usually greater in summer and fall at lower water levels. The 

pond has a very low relative depth (ratio of depth to surface area) and flat bathymetry, and is 

polymictic (mixed continuously) due to the shallow depth and strong local winds. There is little 

spatial variability in water quality conditions in the pond because it is so well-mixed. Water quality 

is strongly related to pond water levels; this is the single most important factor affecting water 

quality. Pond depths and pond water quality are strong controls of pond biota as well (OECD 1982). 

 

Temperature

Mean annual water temperature at Keālia is 76.6	degrees	F and ranges from an average of about 73 

degrees F in winter (December-March) to 79 degrees F in summer (June-September). This is very 

close to the annual average of 75.2 degrees F predicted for water bodies at this latitude. A time series 

plot of hourly water temperature and water level elevation is shown in Figure 3.8. Water temperature 

is strongly dependent on time of day, season, and water level depth. Temperatures are higher and 

fluctuate more with shallow water depths. Daily maximums were as high as 102 degrees F in July 

2003 and 95 degrees F in Sept 2005, when water levels were around 1.0 MLLW or less. The diurnal 

difference in daily minimum and maximum temperatures often exceeds the seasonal variation 

between winter and summer temperatures and can be as great 50 degrees F or more at very low water 

levels (Lewis 1987). 

Salinity

Salinity varies seasonally and interannually in the pond, from fresh to brackish levels in winter to 

hypersaline levels in summer and fall. A time series plot of hourly salinity and water level elevation 

is shown in Figure 3.7. The range in salinity over a single season is large, from values less than 1 ppt 

to values of 70 ppt or more. The maximum salinities observed represent values twice as saline as sea 

water. This must be an extreme physiological stress on organisms living in the pond. Given the 

seasonal fluctuations in salinity, it is almost certainly a strong environmental control of biota in the 

pond. 

The strong seasonal changes in salinity are driven by evaporation and surface inflows. Streams 

flowing into the pond are characterized by very low salinity waters (about 1 ppt). With the initial fall 

flooding of the pond, low salinity stream waters are mixed with residual pond waters, usually of high 

salinity, to produce an initial salinity of 1 to 6 ppt. Salinity usually remains below 6 ppt throughout 

winter and spring until water levels drop to about 2.5 feet MLLW. Below this elevation, there are no 

longer any surface or subsurface outflows, only evaporative losses. As water levels drop below this 

elevation, salinity starts to increase rapidly and predictably, due to evaporative concentration of salts. 

The predicted and observed salinity as a function of elevation below 2.5 feet MLLW is shown in 

Figure 3.7. The observed salinities were measured during the periods of no significant inflows. 

Most of the measured points fall close to the line of predicted values, indicating good agreement. 

Well water from the two production wells at Keālia is fresh (less than 1 ppt) so pumping groundwater 

into the pond can reduce the salinity, depending on the ratio of pond water to well water. 
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3-20 Chapter 3. Physical Environment 

There is a very strong and consistent relationship between water levels and salinity in the pond. The 

fact that the observations closely align with the predicted salinity assuming evaporative concentration 

of salts points to evaporation as being the single major outflow from the pond at levels below 2.5 feet 

MLLW. Since evaporative losses from the pond are predictable, it is possible to predict salinity in 

the short-term as well, in the absence of any significant inflows. 

Figure 3.7. Predicted and observed salinity concentration as a function of water level elevation. 

 

Dissolved Oxygen

Like other field water quality parameters, dissolved oxygen (DO) varies diurnally and seasonally in 

relation to a number of factors. The DO concentration in the pond results from a combination of 

photosynthesis, decomposition, algae biomass or organic matter concentration, temperature, water 

level, and mixing in the pond. Photosynthesis of algae produces DO while respiration of algae and 

decomposition of organic matter consumes it. The higher the algal biomass, the greater the amount 

of photosynthesis, generally speaking, leading to more DO production, at least during the day. On 

the other hand, higher concentrations of organic matter will lead to more decomposition and 

consumption of DO. The diurnal cycle of DO is largely a result of the balance between 

photosynthesis and respiration. 

A time series plots of hourly DO concentrations and water level elevation is shown in Figure 3.8. 

Conditions in Keālia Pond are very productive, causing very large swings in DO on a daily basis, 

with supersaturated DO concentrations during the day (meaning DO concentrations are much greater 

than equilibrium concentrations with atmospheric oxygen) and undersaturated conditions at night 

(meaning DO concentrations are much lower than equilibrium concentrations with atmospheric 

oxygen). Dissolved oxygen, expressed as percent saturation, commonly exceeds 300 percent during 

the day and drops to near 0 at night, particularly at low water levels. The DO concentrations reached 

20 ppm, the maximum measurable with our instrumentation, on numerous occasions. As with 

salinity, the large fluctuations in DO means that it is almost certainly a strong environmental control 

of biota in the pond. 

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Jan-02 Jan-03 Jan-04 Jan-05 Jan-06 Jan-07 

Temperature (F)

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Hourly Temperature or Salinity Hourly Water Level

Figure 3.8. Hourly dissolved oxygen and water level data at Keālia Pond, 2002- 2006.

The solubility of DO is also strongly temperature-dependent, with declining equilibrium DO 

concentrations at warmer temperatures. Photosynthesis and decomposition are temperaturedependent, too. This means diurnal and seasonal temperature variability contributes to DO 

variability. At higher pond depths (3 ft or more) and cooler temperatures, the range of DO is more 

moderate and less likely to become extremely supersaturated or undersaturated. Lower pond levels 

have warmer temperatures, increased photosynthesis and decomposition, and greater chlorophyll- a 

and algal biomass, which produce a wider range of DO conditions. 

pH 

Like DO, pH shows diurnal and seasonal variability in response to many of the same factors. 

Dissolved CO2 is the principal constituent controlling pH in the water column. The CO2 acts as an 

acid in water and lowers the pH. Photosynthesis consumes CO2 and causes pH to increase during the 

day, because of the removal of an acid. Respiration and decomposition produces CO2 and causes pH 

to decline at night, because of the addition of an acid. Seasonal effects on temperatures and water 

levels will affect pH in the same way as DO, through the effects on photosynthesis and 

decomposition. Buffering in the pond may moderate some of the pH swings. 
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3-22 Chapter 3. Physical Environment 

The range of pH in the pond is generally 8.0-9.5, with greater diurnal fluctuation and lower 

minimums (closer to 7.5) at lower water levels (about 2.0 ft or less) (Figure 3.9). The maximum 

daily pH is usually between about 9.0-9.5 but at lower water levels, pH exceeded 9.5 on several 

occasions. At very high water levels, the range of diurnal pH becomes smaller. 

Turbidity 

Turbidity is a measure of the amount of light scattered by suspended solids in the water column. 

Suspended solids have a tremendous effect on the light environment of the pond, thereby affecting 

photosynthesis and primary productivity. The higher the turbidity or the concentration of suspended 

solids, the less light will penetrate into the water column. There is an inverse relationship between 

turbidity and Secchi depth (a measure of water clarity as determined by lowering a black and white 

disk into the water). 

Turbidity in the pond is quite variable and ranges from 0 to greater than 1000 NTU, which is the 

maximum reading on the hydro-measuring device (Figure 3.9). Turbidity is very strongly related to 

water level depths and wind speeds. At shallow depths, algal productivity is great, increasing the 

biomass and solids concentrations in the pond. Mixing depths likely extend all the way to the 

sediment under shallow water levels, which means that any particle or material that has settled can be 

resuspended by wind mixing. Algal biomass and total organic carbon are also important to turbidity 

since these are primary sources of suspended material. As pointed out above, algal biomass increases 

with decreasing pond levels. All of these factors mean that turbidity increases with decreasing pond 

levels. Daily fluctuations in turbidity are correlated with the daily fluctuations in wind speed. 

Seasonally, mixing of settled material is more likely to occur during the dry season because of more 

consistent trade winds and lower water levels. So at lower pond levels, turbidity increases because of 

more efficient wind mixing and greater biomass. 

There are questions as to the origin and cause of turbidity and suspended solids in the pond. Initially, 

we believed that suspended material was being brought into the pond from upland areas through 

tributary streams. While this probably occurred in the past, it does not appear to be now. Even 

substantial surface storm runoff to the pond rarely causes any measureable increase in turbidity or 

total suspended solids in the pond. There is rarely any turbidity increase associated with major 

inflow or abrupt water level increase in the pond. This may be because the large expanse of flat, 

vegetated area upstream and adjacent to the pond functions to slow stream flow and trap sediment. 

Conversion from flood irrigation to drip irrigation in the agricultural lands upstream of the pond in 

the 1970s probably reduced runoff and erosion from these areas as well. Most of the suspended 

material in the pond now is autochthonous organic matter, meaning it is synthesized in the pond 

rather than brought to the pond from the surrounding drainage. 

 
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Figure 3.9. Hourly pH, turbidity, and water level data at Keālia Pond, 2002-2006.

Secchi Depths 

The Secchi is a small circular disk used to measure water transparency. The disk is mounted on 

a line and lowered into the water until it is no longer visible. The depth at which this occurs is 

the Secchi depth. Secchi depth measurements were made weekly or bi-weekly at the pond from 

January 2004-April 2006. Secchi depths ranged from 0.05-1.4 feet and averaged 0.57 feet. 

Secchi depth is negatively correlated with turbidity, total suspended sediments (TSS), volatile 

suspended sediments, total organic carbon, and chlorophyll-a and positively correlated with 

water level depth, with increasing transparency and Secchi depths at higher water levels. As 

such, it varies with water level depths, wind speeds, and algal biomass as a result of the same 

factors responsible for decreasing turbidity, TSS, organic carbon, and chlorophyll-a . 

Macronutrients 

The macronutrients are nitrogen (N) and phosphorus (P). Both are essential for algal growth and both 

will often control algal productivity in the aquatic environment. Total P and total N concentrations 

are high in the pond (median concentrations 0.502 ppb and 4.91 ppb, respectively) but bioavailable 

forms (soluble reactive P, dissolved inorganic N) are very low. The median soluble reactive P (SRP) 

concentration in the pond is 0.007 ppb. The median dissolved inorganic N concentration (DIN) is 

Jan-02 Jan-03 Jan-04 Jan-05 Jan-06 Jan-07 

pH

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Hourly pH or Turbidity Hourly Water Level
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0.028 ppb. Almost all of the nutrients are in particulate form, most likely associated with algae and 

organic matter. This is not unusual in highly productive systems where the demand for bioavailable 

nutrient forms is great. Concentrations of SRP and DIN do spike periodically and these spikes are 

almost always associated with inflow to the pond, suggesting the surface and/or subsurface inflows 

are sources for bioavailable nutrient forms. The stream and piezometer sampling indicates that 

median concentrations of SRP and DIN are higher than the pond, although median concentrations of 

total P and total N are lower than the pond. Surface and subsurface inflows may be important 

sources of bioavailable nutrients for pond algae. 

Concentrations of total P and total N are significantly greater in the summer than in the winter. The 

median July-October summer concentration is 0.79 TP ppb and 7.1 TN ppb and the median JanuaryApril winter concentration is 0.37 TP ppb and 3.1 TN ppb, respectively. The higher concentrations 

in the summer are likely due to several factors including evaporative concentration (the same process 

that concentrates salts in the summer). They may also indicate a source of internal nutrient loading 

from the sediments or a nutrient contribution from groundwater seepage inflow. Most of the algae in 

the pond are not cyanobacteria so they are not obtaining N through the atmosphere. At low water 

levels, total nutrient concentrations can become extremely high. Total P concentrations reached 

peaks of 11.2 ppb in July 2003 and 9.5 ppb in August 2005. Total N concentrations reached 45.0 ppb 

and 60.8 ppb during the same months. These high concentrations corresponded to the minimum 

water levels for the respective years. 

Chlorophyll-a 

Chlorophyll-a is the green pigment found in plants that allows them to convert sunlight to energy. 

Chlorophyll-a measurements indicate the biomass (weight) of phytoplankton in the pond and the 

primary productivity of the pond. Keālia Pond is quite productive, with chlorophyll-a 

concentrations greater than 8,000 ppb observed in July 2003 and greater than 3,000 ppb in July 2005. 

These are extremely high concentrations and they coincide with the timing of nutrient peaks 

described above. Chlorophyll-a and algal biomass affect many other things in the pond: turbidity, 

dissolved oxygen levels, pH, organic carbon, nutrient cycling, light attenuation, and possibly food 

resources for invertebrates and higher biota such as fish and waterbirds. 

Chlorophyll-a is inversely related to pond elevation. Lower water elevations generally correspond to 

periods of higher algal biomass. Light may be a limiting factor for algal growth, especially at higher 

water levels. While turbidity, TSS, algal biomass, and total oxygen content (TOC) decrease at high 

water levels, allowing more light penetration, there is still a significant amount of the water column 

that is without light. Under these conditions, winds could mix algae in and out of the photic zone and 

limit the time they spend in the photic zone. 

Chlorophyll-a concentrations appear to build during quiescent periods with little water level change, 

especially at the lower water surface elevations (less than about 2.0 ft). Chlorophyll-a concentrations 

typically reach their annual peak at minimum water elevations. The high concentrations observed in 

July 2003 corresponded to the minimum water elevation (0.82 ft) for the year. Annual maximums in 

fall 2001 and fall 2002 corresponded to water elevations of about 1.6 feet in both years. 

Dissolved Si 

Soluble reactive Si (SRS) is the soluble, bioavailable form of Si. This element is an essential nutrient 

for diatoms, which represent two-thirds of the total biovolume of algae in the pond. The 
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Chapter 3. Physical Environment 3-25 

concentration of SRS varied considerably in Keālia Pond, with a median concentration of 2.5 ppb 

and a range from less than 0.1-17.1 ppb. Approximately 10 percent of the water samples had 

concentrations below the detection limit of 0.1ppb.The concentration of SRS tended to be lower with 

greater diatom biovolume, but the relationship was not very strong. Other factors like water depth, 

light availability, macronutrient concentrations, and salinity, may be controlling diatoms as well. 

Algae 

High salinity, sediments, turbid waters, and wind driven waves limit the growth of any rooted 

emergent or submergent vegetation and favor the growth of phytoplankton in the main pond. 

Algae are responsible for most of the primary productivity in the pond and were monitored 

regularly at the pond from 2002-2005. The following information is based on the results from 

this monitoring. 

The species, densities, and biovolume of algae varied considerably in the pond seasonally and 

interannually (Figure 3.10). There was an average of 11 species of algae in the pond. Reynolds 

(1994) states that nutrient-rich environments will usually have fewer niches to exploit and 

therefore, fewer number of algae species. The three most common algal groups were diatoms, 

green algae, and blue-green algae or cyanobacteria, as is common in small, highly enriched water 

bodies. Diatoms were the dominant group, representing an average of 67 percent of the total 

biovolume of algae in the pond. Green algae were the second most dominate algal group. 

Generally speaking, diatoms and green algae seem better adapted to fluctuating light conditions 

in well-mixed waters than cyanobacteria. Being non-motile and non-bouyant, they typically 

occur in well-mixed waters whereas positively bouyant algae, like planktonic cyanobacteria, 

persist in stable waters and still, windless conditions. 

Figure 3.10. Algal group biovolume as a percent of total biovolume at Keālia Pond, 2002-2005. 

0%

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Dec-01 Jun-02 Dec-02 Jun-03 Dec-03 Jun-04 Dec-04 Jun-05 Dec-05

Greens 

Diatoms

Blue-Greens 

Other
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All of the algae in the pond are generally smaller-bodied, planktonic algae, with higher growth rates 

and lower sinking losses. They are generally tolerant of a wide range of salinities and light 

environments and typically found in nutrient-rich waters. Most were non-flagellate, most were small 

(geometric mean biovolume is 134 um3

 per cell), and many were osmotrophic. The dominance of 

diatoms and other small-bodied algae may be because the pond is continually disturbed through 

wind-mixing, and run-off events, causing perennial “spring-like” conditions in this system. Very 

shallow lakes are often arrested in a single successional stage, which explains their greater simplicity 

and lower degree of seasonal variation in phytoplankton communities (Lewis 1996). 

3.5 Topography/Bathymetry 

The area around Keālia Pond has undergone substantial changes since the 1900s. Reportedly, 

Native Hawaiians used the pond for an easy supply of ‘ama‘ama and o‘opu and salt was mined 

from the northeast shore of the pond by European visitors. During the 1920s and 1930s, 

accelerated erosion from agricultural development upstream of the area likely caused a great deal 

of sedimentation in the pond. Combined with the diversion of inflows, the pond depth and 

volume were reduced substantially. Since the 1930s, the pond has been intermittently dry, 

probably due to a combination of sedimentation from the surrounding agricultural development 

and alteration and diversion of surface flows to the pond (Smith and Medeiros 1952). 

The apparent decrease in pond depth and capacity has generated a lot of interest and concern 

about sedimentation in the pond. One of the factors driving this concern is the dust that blows 

from the exposed sediments of the pond bottom during periods when the pond is dry. Dry 

periods in the pond during summer correspond with the season of maximum wind speeds and 

frequencies. The blowing dust may be viewed as a potential ecological threat to the coral reefs; 

however, Maciolek (1971) postulated the dust had little impact on the reefs and is less 

detrimental than the sedimentation from the outlet stream when all sediments are discharged at 

once. 

An obvious concern is that the reduced depth and capacity of the pond has resulted in an increase 

in the frequency of dry conditions and exposed sediments in the pond. Several earlier studies 

have been focused on the question of whether or not the pond is filling in due to sedimentation 

and, if so, at what rate. In the 1970s, there were three elevation surveys of the pond and the 

surrounding area to address this question. These were done by the U.S. Army Corps of 

Engineers (USACE) in 1970, NRCS in 1972, and the Service in 1976. 

In addition to the survey capacity curve, the NRCS did a sedimentation study in conjunction with 

an environmental assessment of the area by Maui Electric Company at the request of the Maui 

Planning Commission. Based on the survey and the sedimentation study, the NRCS estimated 

that the capacity in 1910 was about 450 acre-feet and that there was a 55 percent loss of capacity 

in the pond from 1910-1972 due to sedimentation. The corresponding pond elevation at 450 

acre-feet capacity is not stated in the report, and it is hard to compare it to other more recent 

capacity estimates without knowing the assumed water level elevation. Applying the 55 percent 

capacity loss to the 1910 estimate of a 450 acre-feet pond means that the 1972 pond capacity was 

about 200 acre-feet. 
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Chapter 3. Physical Environment 3-27 

Figure 3.11 – Elevation & Contours 
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3-28 Chapter 3. Physical Environment 

To preserve the quality of this figure, this side was left blank intentionally. 
 Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 3. Physical Environment 3-29 

Included in the 1972 sedimentation study was an estimated sediment budget for the pond. In 

1972, the pond was estimated to be receiving 10.5 acre-feet of sediment annually with about 5 

acre-feet of this accumulated sediment lost to wind erosion and another 2.3 acre-feet lost to the 

bay, leaving a net addition of 3.2 acre-feet in the pond. The sedimentation estimates emphasize 

the importance of dry conditions and deflation to the pond. The pond acts as a settling and 

deflation basin maintained by wind erosion of deposited silt. If the pond were permanently 

inundated, this would preclude deflation and may actually tend to channelize drainage directly to 

the ocean. While the blowing dust is a nuisance issue to neighboring residents, Maciolek (1971) 

did not believe the blowing dust is harming coral reefs offshore, pointing out that much of the 

material is deposited further, beyond inshore Mā‘alaea waters. 

Figure 3.12. Pond volume and area as a function of water level elevation, USFWS 2000. 

A current elevation survey of the pond was one of the most important information needs 

identified by a Service workshop in 2000. In October 2000, the Service completed an elevation 

survey of the pond. The results of that survey are shown in Figure 3.11 and 3.12. It is not clear 

that the datums for the older surveys are accurate and comparable to the newer survey 

information. However, if the pond has continued to accumulate 3.2 acre-feet of sediment per 

year as estimated in 1972, then an additional 100 acre-feet or more of capacity should have been 

lost by now. This would represent a 50 percent loss of the estimated capacity in 1972, which 

appears unrealistically high based on observations by Refuge staff. 

Changes in land use and water management upstream may have affected the sediment input to 

the pond. Most of the sugarcane fields in the area were converted from furrow irrigation to drip 

irrigation in the 1970s. Engot and Vanna (2007) report that furrow-irrigation efficiency ranges 

Water Level Elevation (MLLW)

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from 0.3-0.7 while drip-irrigation efficiency ranges from 0.8-0.95. More efficient irrigation in 

recent years has likely reduced erosion and runoff into the pond. This seems to be confirmed by 

the recent survey information and water quality monitoring, which does not indicate much 

sediment input into the pond. Much of the suspended material in the pond is organic and 

autochthonous. It seems that the pond is no longer accumulating sediment as it did historically 

(Wilcox 1996). 

3.6 Environmental Contaminants 

A study of environmental contaminants at Keālia Pond NWR was completed in 1992, prior to its 

establishment as a Refuge. The purpose of the survey was to determine contaminant concentrations 

within and adjacent to the proposed acquisition boundary, specifically for pesticides, heavy metals, 

petroleum byproducts, and certain physical parameters (e.g., particle size of sediment). Given the 

history of the property and adjacent lands at the time, these analyses were essential in identifying the 

present and future quality of the wetland (USFWS 1992). 

The chemical analyses for approximately 80 pesticides and related breakdown product residues were 

at levels below the analytical detection limits of the pesticide scan for samples within the Refuge 

boundary; therefore, no detectable levels of pesticides were reported for soil samples collected. 

These results corroborate a 1986 contaminant survey of Keālia Pond which reported no detectable 

levels of pesticides, including lindane, heptachlor epoxide, heptachlor, aldrin, DDD, DDT, ametryn, 

and atrazine. These results suggest that soils at the Refuge are neither pervasively nor acutely 

contaminated with traditional persistent pesticides above analytical detection limits of the scan. 

These findings were unexpected given the long history of agriculture within the Waikapū watershed. 

The study also included chemical analyses for 20 heavy metal compounds (mercury, lead, arsenic, 

cadmium, chromium, copper, nickel, selenium, and zinc) from soil samples. With the exceptions of 

cadmium, chromium, and nickel, the results did not indicate widespread or pervasive contamination 

by heavy metals within the Refuge. Detectable levels of these exceptions were thought to be due to 

the historical and then current use of the property by the military and aquaculture facilities (see Land 

Use section 3.7). 

Site inspection screening was performed during this same period, concentrating in areas of historical 

use within and beyond the Refuge boundary, and areas used by the operational aquaculture facilities. 

Evidence of petroleum-based waste was observed; however, the sources were identifiable. These 

sites included areas around the old Maui airport at Mā‘alaea Flats along with over 40 abandoned 

vehicles, and household and industrial items. Many of these sites were beyond the final boundary 

delineation; however, they remain in the wetland within a much larger watershed and pose a potential 

risk to wildlife and habitat. Following the contaminants survey and prior to the acquisition, most of 

the potential contaminant sites had been remediated by the landowner (A&B Properties) or their 

tenants. 

The aquaculture facility was in operation in 1992 and was also evaluated for contaminants. 

Unlabeled bags, bottles of chemicals, and oil patches in and around the former laboratory were 

observed. These were cleaned up or removed by the County of Maui in accordance with their lease 
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Chapter 3. Physical Environment 3-31 

agreement with A&B Properties. Maui Electric Company surveyed their pole-mounted electrical 

transformers within the Refuge and replaced one transformer that contained regulated levels of 

polychlorinated biphenyls (PCBs). Currently, all transformers within the Refuge contain non-PCB 

fluid. 

The Refuge will always be subjected to activities occurring in the upper watershed, thus it is 

beneficial to periodically re-evaluate the soils. For this reason, a contaminants study was conducted 

in 2001 to determine contaminant levels in superficial sediments throughout the pond and streams 

that supply run-off and assess potential hazards to aquatic biota. Of the 129 possible contaminants, 

12 tests resulted in detectable levels of organic contaminants (polyaromatic hydrocarbons, acetone, 

and methyl chloride). Polyaromatic hydrocarbons result from emissions of gasoline engines and 

municipal incinerators; whereas volatile organics (acetone) result from domestic and industrial 

solvents as well as emissions of gasoline engines. Although organic contaminants were detected in 

sediment samples, none of these contained concentrations above effects levels (Kilbride 2002). 

Endangered waterbird and migratory bird tissue is sampled only when dead birds are retrieved from 

the wetland and submitted to the USGS National Wildlife Health Center in Honolulu. Aside from 

testing for avian diseases, the tissue is analyzed for lead. To date, lead has not been detected in birds 

from the Refuge. A small sample (10) of live tilapia was collected from Keālia Pond in 1999 to test 

for organic contaminants. Results indicated no detectable levels in the tissue. The fish in the pond 

have yet to be sampled for metals. 

Changes in upstream land use and presence of agricultural fields since the early 1900s have resulted 

in deposition of sediments within the soil profile of the pond. The potential for contaminants 

entering into the Refuge will continue to be a concern and requires periodic monitoring to prevent 

accumulation into the habitat and wildlife species. 

3.6.1 Molokini Contaminants 

The USACE has designated Molokini and 157 acres of the surrounding waters as Unexploded 

Ordnance Removal, FUDS site, and confirmed the site has munitions and explosives of concern

originating from military activities. The Navy was tasked to conduct a surface survey of Molokini. 

Two site surveys conducted in December 2006 and March 2007 found three ordnance items that had 

to be disposed of prior to the turnover of islet: a 250lb old-style bomb, a 105mm projectile, and a 5-

inch rocket with 3.25-inch motor. 

3.7 Land Use 

A diversity of land uses occur in the vicinity of Keālia Pond NWR, a majority of which is in 

agriculture. The towns of Kīhei and Mā‘alaea are nearby the Refuge to the east and west, 

respectively. One of the two power plants operated by Maui Electric Company borders the Refuge to 

the west. The Waikapū watershed, beyond the Refuge boundary, has residential and commercial 

development. 
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3-32 Chapter 3. Physical Environment 

Since the early 1900s, sugarcane has been the predominant crop cultivated within the lower sections 

of the watershed and the fields surrounding the inland margins of the Refuge boundary. The three 

channelized streams that feed into Keālia Pond from West Maui Mountains have been diverted to 

irrigate the sugarcane fields creating minor flow to the ocean. Agricultural activities over the years 

have drastically altered the landscape of the watershed through excessive vegetation clearing and 

subsequent downstream sedimentation (Maciolek 1971, USFWS 1978). 

Hawaiian Commercial & Sugar Company operates the only sugarcane plantation in Maui County and 

Hawai‘i as a whole. HC&S owns the 34,900-acre plantation surrounding Keālia Pond and produces 

over 172,000 tons of raw sugar annually. In addition, HC&S employs over 900 Maui residents. 

Currently, the company is researching new commercial uses of sugarcane, including alternative fuel 

(Maui County 2009). 

On the northwest side of the Refuge boundary is the Maui Electric Company’s Mā‘alaea Power 

Plant. The company’s high voltage electric transmission line runs from the Mā‘alaea Power Plant 

east towards Kīhei, between the Refuge’s north boundary and the sugarcane fields. 

The Puanani o Kula nursery, operating since 1989, is adjacent to the Refuge’s east boundary. This 

landscaping operation grows both native and exotic plants on land leased from A&B Properties. The 

KNUI radio transmitting facility is also located on their property. 

The closest town to the Refuge is Kīhei, with condominiums starting across the eastern side of the 

Refuge along Mā‘alaea Bay. Occupants of these buildings include full- and part-time residents and 

vacationers. Constructed in the early 1970s, the largest condominium is Sugar Beach Resort with 

more than 200 units. Continuing east, South Kīhei Rd. follows the shoreline with commercial 

development (resorts, condominiums, businesses) and residential housing. 

A couple of transportation corridors are adjacent to the Refuge. Mokulele Hwy. is 6.5 miles in 

length and situated north-south, connecting the towns of Kahului and Kīhei. The Refuge’s entrance 

road is off this four-lane highway. The south boundary is bounded by N. Kīhei Rd. that bisects the 

Refuge from Mā‘alaea Bay. This two-lane highway separates Keālia Pond (open water pond and 

flats) from Mā‘alaea Flats. The coastal property parallel with N. Kīhei Rd. is narrow, approximately 

1.25 miles long, and owned by A&B Properties from the road right-of-way to the high water line. 

This property continues westward to the Mā‘alaea community along the south boundary of the 

Refuge’s Mā‘alaea Flats. 

Land use beyond the Refuge’s boundary includes the community of Mā‘alaea, located more than 3 

miles west of the Refuge. This area is primarily condominiums adjacent to Mā‘alaea Harbor 

(developed in the 1950s) where numerous tour boats are docked. A new residential community at 

Mā‘alaea (Ohana Kai Village) is currently under construction and will include 1,100 single-family 

homes within 257 acres at the intersection of N. Kīhei Rd. and Honoapi‘ilani Hwy. and adjacent to 

Pōhākea Stream. A rock quarry and construction dump site is also located at this intersection on the 

southwest side of Pōhākea Stream. 

The former Naval Air Station Pu‘unēnē is less than 1 mile northeast of the Refuge and 

topographically directly upgradient. This area is currently used for drag racing and is behind the 

National Guard’s training center off Mokulele Hwy. Further up the gradient within the Waikapū
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Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 3. Physical Environment 3-33 

watershed, beyond the sugarcane fields, is the town of Waikapū consisting of residential and 

commercial development. Elevation above the town’s housing area is too steep for development. 

3.7.1 Previous Land Uses 

The first Maui airport was constructed at Mā‘alaea Flats in 1929. On November 11, 1929, the first 

scheduled air service from Honolulu to Maui was inaugurated. Planes used were eight-passenger 

Sikorsky S-38 Amphibians. Mā‘alaea Airport was a level dirt field and was unusable in wet 

weather. In 1935 the Inter-Island Airways began adding 16-passenger Sikorsky S-43s to its fleet; 

however, the field was too small and too close to the mountains to meet desired safety criteria. Due 

to these safety concerns, the airport was moved to Pu‘unēnē, a few miles north of the Refuge. 

Evidence of the paved runway from this former airport, now almost completely obscured by 

vegetation, can still be seen in the Mā‘alaea Flats, beyond the Refuge boundary. A number of small 

concrete pads or foundations are in the vicinity of the airport runway. Two large concrete 

foundations, approximately 100 ft. square, are on the west of the former runway (USFWS 1992). 

During World War II, the military used Mā‘alaea Flats for training activities. A concrete wall, 

approximately 100 feet long and 15 feet tall, oriented parallel to the shoreline with soil piled up to the 

top of the wall on the mauka side. The 1954 USGS Mā‘alaea Quadrangle refers to this structure as a 

“Sea Wall”. Longtime local residents remember this structure as a gunnery range used by the 

Marines for military training. The Navy used Molokini for target bombing practice because its size 

and shape was somewhat similar to a battleship. 

Anecdotal information implied a potential landfill was located in Keālia Pond; however, the County 

of Maui Department of Public Works, whose file information on landfills begins in the late 1960s, 

has no information on this possible landfill. In addition, this landfill could not be located during the 

preacquisition contaminants survey conducted in 1992. Mink (2000) mentions the use of the pond as 

a rubbish dump between 1925 and 1930 but there is no official record of this use. It is probable that 

illegal dumping of residential and commercial waste did occur, however. 

In 1970, Fish Farms Hawai‘i leased 25 acres of land on the northern boundary of the pond to harvest 

Malaysian prawn (Macrobrachium rosenbergii). Pacific Aquaculture Corporation purchased this 

commercial operation in 1972. Due to poor water quality, prawn aquaculture ceased and Pacific 

Aquaculture Corporation began generating approximately 100,000 pounds of catfish (Ictalurus 

punctatus) annually. Cultivation of a catfish species (Clarias sp.) began in 1984 after Pacific 

Aquaculture Corporation sold the facility to Maui County. When Keālia Pond NWR was established 

in 1992, the aquaculture facility was called Keālia Fish Farm, Inc. This facility stopped operations on 

September 30, 1995, and Keālia Fish Farm, Inc. officially closed on December 31, 1995. The 

Refuge still uses these ponds; however, they have been redesigned for waterbirds and access by the 

public. In 2005 the Refuge hired a contractor to redesign the old Keālia Fish Farm ponds for bird use 

and installed water distribution lines (Maciolek 1971, Shallenberger 1977). 

On the west side, near the Mā‘alaea Power Plant, Maui County funded a project in 1978 to provide 

an alternate source of baitfish for the aku fishery. The project raised Cuban molly along with 

‘ama‘ama (striped mullet) and ‘awa (milkfish). Funding for the project ended in 1987. The ponds 

were partially restored 1990-1998 when a County-funded program used the area. These small ponds 

(still called the Baitfish Ponds) are within the Refuge and managed for endangered waterbirds. In 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

3-34 Chapter 3. Physical Environment 

2007, the Refuge combined the original six small ponds into one wetland management unit and 

installed a pump on the existing sump to flood the pond, as needed. Use of the area within the 

Refuge boundary for cattle is evident from kiawe posts, barbed wire in forested habitat, and water 

troughs but the period in time is unknown (DeLeon 1987). 

3.7.2 Molokini Land Use 

Molokini was withdrawn from lands ceded by the Republic of 

Hawai‘i to the United States of America and set aside by Territorial 

Governor W. F. Frear on September 13, 1910, to be administered by 

the USCG for lighthouse purposes. In 1911, a 16-foot-tall tower was 

erected on the southwest rim of the crater where it had a focal plane 

of 173 feet above the water. Rabbits were introduced some time 

around 1915 but apparently died out on their own by the 1960s. 

In 1925, the Molokini light tower was replaced by another tower 

187 feet above the water. This second light marked Molokini for 22 

years until it was replaced in 1947 by another tower, which 

displayed an electric light powered by batteries stored in a shack 

built inside the base of the tower. In April of 1989, a powerful storm 

toppled the 1947 tower and sent it tumbling down the crater. The 

USCG erected a temporary beacon and later the metal pole and 

solar-powered US Aids to Navigation System light that they 

currently maintain on the islet (Dean 1991). 

The marine environment surrounding Molokini, beginning from the high water mark at the islet 

shorelines to depths of 180 feet (30 fathoms), has been designated by the State of Hawai‘i as the 

Molokini Shoal Marine Life Conservation District, managed by DLNR and further included in 

NOAA’s Humpback Whale National Marine Sanctuary. 

Molokini navigation aid beacon

© Forest & Kim Starr
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 4. Refuge Biology and Habitat 4-1 

Chapter 4. Refuge Biology and Habitat 

This chapter addresses the biological resources and habitats on the Refuge. The chapter begins with a 

discussion of biological integrity. It then presents pertinent background information for each 

conservation target identified in the CCP. 

4.1 Biological Integrity Analysis 

The Administration Act directs the Service to ensure that the biological integrity, diversity, and 

environmental health (BIDEH) of the Refuge System are maintained for the benefit of present and 

future generations of Americans. The Service’s policy on BIDEH (601 FW 3) also provides guidance 

on consideration and protection of the broad spectrum of fish, wildlife, and habitat resources found 

on refuges, and associated ecosystems that represent BIDEH on each refuge. 

Biological integrity lies along a continuum from a completely natural system to a biological system 

extensively altered by considerable human impacts to the landscape. No modern landscape retains 

complete BIDEH. However, we strive to prevent the further loss of natural biological features and 

processes. Maintaining or restoring biological integrity is not the same as maximizing biological 

diversity. Maintaining biological integrity may entail managing for a single species or community at 

some refuges and combinations of species or communities at other refuges. Maintaining critical 

Mā‘alaea Flats Laura Beauregard/USFWS
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

4-2 Chapter 4. Refuge Biology and Habitat

habitat for a specific endangered species, even though it may reduce biological diversity at the refuge 

scale, helps maintain biological integrity and diversity at the ecosystem or national landscape scale. 

On refuges, we typically focus our evaluations of biological diversity at the refuge scale; however, 

these refuge evaluations can contribute to assessments at larger landscape scales. We strive to 

maintain populations of breeding individuals that are genetically viable and functional. Evaluations 

of biological diversity begin with population surveys and studies of flora and fauna. The Refuge 

System’s focus is on native species and natural communities such as those found under historical 

conditions. We strive to manage in a holistic manner the combination of BIDEH. We balance all 

three by considering refuge purpose(s), Refuge System mission, and landscape scales. Where 

practical, we support the return of extirpated native species in the context of surrounding landscapes. 

The BIDEH of the Keālia Pond NWR (Table 4.1) and its watersheds have undergone major 

alterations since pre-settlement times, primarily by agricultural practices and urbanization. There are 

ditches and sluice gates that were built at least 400 years ago to let fish such as awa and ‘ama‘ama 

into the pond. Large scale sugarcane and pineapple farming began sometime in the early 1900s, 

operations that eventually covered the lower elevations of central Maui. Any large acreage not in 

pineapple or sugarcane production was occupied by cattle ranching. 

Little is known about the pristine coastal wet vegetation due to early Polynesian settlers creating 

fishponds and irrigated farmlands in the area. A small number of native plants still occur at Keālia 

Pond, but their distribution before introduction of non-native species is difficult to reconstruct. By 

the early 1900s, upland conversion to farming dewatered streams that discharged into Keālia Pond. 

This would have reduced the size of the wetlands, increased salinity levels, and likely reduced plant 

diversity. The vegetated wetlands are now dominated by invasive pickleweed. Native plants 

common in this habitat are kaluha and ‘akulikuli with few pockets of makaloa and ‘ele. 

Statewide migratory waterfowl numbers have shown a large decline since the 1950s. At Keālia 

Pond, koloa māpu numbers fluctuated in the 1950s, but peak numbers are similar to the past 10 years. 

However, peak koloa mohā numbers had a large decline since the 1950s. Most of the common 

shorebirds inhabiting Keālia Pond may also occur in non-wetland habitats. At Keālia Pond, counts of 

kōlea (Pacific golden-plover), ‘ūlili (wandering tattler), ‘akekeke (ruddy turnstone), hunakai 

(sanderling) show no obvious trends. 

Nonnative mosquito fish and tilapia are the dominant fish species in Keālia Pond. We have 

monitored the fish population since the late 1990s. Large tilapia die-offs frequently occur when the 

water level recedes. The decomposing fish can produce a strong odor that permeates nearby 

neighborhoods. However, over the past several years, the biomass of dead fish has declined. This is 

probably due to recent drought conditions that reduced the residence time of deep water at Keālia 

Pond. Tilapia did not have sufficient time to grow and produce large populations as observed in the 

1990s. In the past five years we had three fish kills, but the last major die-off occurred in 2005. 

 

 
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Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 4. Refuge Biology and Habitat 4-3 

Table 4.1. Biological Integrity, Diversity, and Environmental Health Characteristics. 

Habitats Population/Habitat 

Attributes 

Natural processes 

responsible for these 

conditions 

Limiting Factors 

Emergent 

wetland 

Seasonal, semi-permanent, 

permanent 

Potential conservation 

species: endangered 

waterbirds, migratory 

waterfowl, and shorebirds 

Periodic flooding; 

seasonal fluctuations/ 

drying, but more 

permanent water 

situations than typical 

seasonal wetlands 

Pest species (California grass, 

California bulrush, marsh 

fleabane, pickleweed, red 

mangrove; mongoose, rats, cats 

and dogs); ditching, dikedimpoundments; limited 

quantity and control of water 

resources; diverted and 

unpredictable surface water 

flow; and human development 

Coastal 

mudflat 

Seasonal 

Potential conservation 

species: endangered 

waterbirds and, migratory 

shorebirds 

Periodic flooding; 

seasonal 

fluctuations/drying 

Pest species (pickleweed, 

mongoose, rats, cats, and 

dogs); limited water 

availability and control; road 

kills of endangered species 

along N. Kīhei Rd. 

Coastal 

dunes 

Beach strand/dune 

communities 

Potential conservation 

species: seabirds, 

shorebirds, endangered 

‘īlio-holo-i-ka-uaua and 

honu ‘ea, threatened honu 

Onshore winds, salt 

spray, sandy soil, wave 

and tidal action 

Pest species (marsh fleabane, 

kiawe, buffle grass); 

pickleweed, spiny amaranth, 

mongooses, rats, cats, dogs, 

human disturbance; marine 

debris, and SLR 

Coastal 

dry forest 

and 

shrubland 

Naupaka kahakai, 

hinahina, ‘ilima, nai‘o 

Potential conservation 

species: ‘ōka‘i ‘aiea, 

seabirds, shorebirds 

Windblown accumulation 

of sand; extreme high 

water flooding – 

seasonal; salt spray 

Pest species (kiawe, Guinea 

grass, Bermuda grass; marsh 

fleabane, rats, cats and dogs); 

human disturbance 

(squatting/camping); vehicular 

access and damage; wind and 

water erosion 

Offshore 

islet 

Seabirds, native plants 

Potential conservation 

species: seabirds, ‘ihi 

 

Isolated eroding cinder 

cone; ocean winds, salt 

spray, volcanic tuff soil, 

wave action 

Pest species (buffel grass and 

ants) 

 

 
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Draft Comprehensive Conservation Plan and Environmental Assessment 

4-4 Chapter 4. Refuge Biology and Habitat

4.2 Conservation Targets 

Conservation targets are those species or habitats 

that are most important to the management of the 

Refuge. Management for these focal species and the 

habitats that support them will benefit other native 

species that are present on the Refuge. Table 4.2 

identifies the priority resources of concern for Keālia 

Pond NWR. As native species are referenced by 

their Hawaiian names, Appendix A contains a list of 

all scientific, English common names, and Hawaiian 

names. 

4.2.1 Conservation Target Selection 

In preparing this plan, the Service reviewed other local, regional, and national plans that pertain to 

the wildlife and habitats of the Islands of Maui and Molokini. The Service also sought input from 

Hawai‘i State conservation agencies, non-governmental organizations, and the general public. The 

Refuge purposes (see Chapter 1) were carefully reviewed as was the Refuge’s contribution to 

maintenance of BIDEH. Potential management actions will be evaluated on their effectiveness in 

achieving Refuge goals and objectives for the priority resources of concern. 

Table 4.2. Priority Resources of Concern. 

Focal 

Species Habitat Type Habitat Structure Life History Requirements 

Other Benefiting 

Species 

‘Alae 

ke‘oke‘o 

Flooded wetlands Open water 

(< 18 in. depth) 

Foraging, loafing Migratory 

waterfowl, 

shorebirds, ‘alae 

‘ula, and koloa 

maoli 

Emergent wetland Hemi-marsh with 

kaluhā sedge 

Nesting, brood 

rearing, cover 

Mudflats Moist, saturated 

soil 

Foraging, loafing 

Levees Ground cover 

vegetation 

Foraging, loafing 

Ae‘o 

Flooded wetland Shallow water 

(< 7 in. depth) 

Foraging, loafing Migratory 

waterfowl, 

shorebirds, ‘alae 

‘ula, ‘alae 

ke‘oke‘o, and 

koloa maoli 

Mudflats Adjacent 

vegetation (cover) 

and shallow water 

Nesting, brood 

rearing 

Ae‘o chick Laura Beauregard/USFWS
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 4. Refuge Biology and Habitat 4-5 

Focal 

Species Habitat Type Habitat Structure Life History Requirements 

Other Benefiting 

Species 

‘Īlio-holo-ika-uaua

Beach areas; sand 

spits and islets, 

including all beach 

crest vegetation; 

inner reef waters; 

and open ocean 

Sandy shoreline, 

rocky areas, and 

emergent reefs; as 

well as vegetated 

areas for shelter 

Pupping, nursing, 

resting, and 

molting 

Honu, shorebirds, 

and seabirds 

Honu 

Dunes and coastal 

strand; shallow, 

protected water 

with abundant 

aquatic vegetation; 

coral reefs; sand 

spits and islets; and 

open ocean 

Open beaches with 

a sloping platform 

and minimal 

disturbance are 

required for nesting 

Basking and 

nesting 

‘Īlio-holo-i- kauaua, honu ‘ea, 

shorebirds, and 

seabirds 

Honu ‘ea 

Dunes and coastal 

strand; shallow, 

protected water 

with abundant 

aquatic vegetation; 

coral reefs; sand 

spits and islets; and 

open ocean 

Compacted sand; 

open beaches with 

a sloping platform 

and minimal 

disturbance are 

required for nesting 

Nesting ‘Īlio-holo-i- kauaua, honu, 

shorebirds, and 

seabirds 

‘Ōka‘i ‘aiea 

Dry to mesic forest 

and shrubland; host 

plants such as 

Nothocestrum spp.; 

native nectar 

sources including 

koaliawa, Ipomoea, 

maiapilo, and 

‘ilie‘e 

Sea level to 5,000 

ft elevation, native 

shrubs and trees 

Adult and larval 

feeding and 

reproduction 

Native plants, 

moths, and 

butterflies 

‘Ihi 

Leeward coasts of 

the Islands of 

Molokini and 

Kaho‘olawe; under 

extremely dry 

conditions

Volcanic tuff, loose 

rock at the base of 

sea cliffs and on 

steep rocky slopes 

Propagation, 

germination, 

growth 

Native plants, 

seabirds 

Management of Refuge focal species and habitats that support them will benefit many of the other 

native and migratory species that are present on the Refuge. Our management priorities may change 

over time and since the CCP is designed to be a living, flexible document, changes will be made as 

needed and at appropriate times as identified by Refuge personnel. Our conservation targets for 

management are grouped by system and species (Table 4.3). 

 
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Draft Comprehensive Conservation Plan and Environmental Assessment 

4-6 Chapter 4. Refuge Biology and Habitat

Table 4.3. Conservation targets for the CCP. 

System Targets Benefiting Resources 

Wetland and deepwater 

habitat Migratory waterfowl, shorebirds, and endangered waterbirds 

Dunes habitat ‘Īlio-holo-i-ka-uaua, honu, honu ‘ea, shorebirds, and native plants 

Upland shrub/forest 

habitat Native plants and endangered ‘ōka‘i ‘aiea 

Molokini Islet habitat Native plants, nesting and roosting seabirds, wintering waterfowl, and 

other migratory birds 

Species Group Targets Benefiting Resources 

Endangered species ‘Īlio-holo-i-ka-uaua, ae‘o, ‘alae ke‘oke‘o, honu ‘ea, and ‘ōka‘i ‘aiea 

Waterbirds All waterbirds, migratory waterfowl 

Shorebirds All migratory shorebirds 

Seabirds All birds that frequent coastal waters and nest and/or loaf on Molokini 

 
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Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 4. Refuge Biology and Habitat 4-7 

4.3 Endangered Hawaiian Waterbirds 

Keālia Pond NWR was established to provide protected habitat for two of Hawai‘i’s endangered 

waterbirds, the ae‘o and ‘alae ke‘oke‘o. Statewide, the primary causes of their population decline 

include loss of wetland habitat, predation by introduced animals, altered hydrology, habitat alteration 

by invasive non-native plants, and disease. In addition, environmental contaminants may also 

potentially threaten populations in certain areas. No critical habitat has been designated for any of 

Hawai‘i’s endangered waterbirds. 

The general recovery objectives for the endangered waterbirds, as described in the Draft Revised 

Recovery Plan for Hawaiian Waterbirds, are the following: stabilize or increase species populations 

to greater than 2,000 individuals; establish multiple self-sustaining breeding populations throughout 

their historic ranges; protect and manage core and supporting wetlands Statewide; eliminate or 

control the threat of introduced predators, diseases, and contaminants; and remove the Statewide 

threat of the koloa maoli hybridizing with mallards. 

4.3.1 Ae‘o (Himantopus mexicanus knudseni) or 

Hawaiian Stilt 

The ae‘o is an endemic subspecies in the Hawaiian Islands, which 

is part of a superspecies complex of stilts found in various parts of 

the world. The State population of this shorebird fluctuates 

between 1,200-1,500 birds with a 5-year average of 1,350 birds. 

Adult and juvenile dispersal has been observed both intra- and 

inter-island. As many as 1079 ae‘o have been observed at the 

Refuge at one time (Figure 4.1). The count of over 1,000 birds 

in 2003 was also 50 percent of the Statewide population 

criterion for delisting the ae‘o (USFWS 2005, Robinson et al. 

1999). 

Ae‘o favor open wetland habitats with minimal vegetative cover 

and water depths less than 9.4 inches, as well as tidal mudflats. 

Ae‘o nest from April-July in simple scrapes on low relief islands or 

on exposed flats around the perimeter on the main pond after water has receded (Figure 4.2). They 

will use ephemeral wetlands to exploit seasonal abundance of food, feeding on small fish, crabs, 

polychaete worms, terrestrial and aquatic insects, and tadpoles. Known predators include barn owls, 

pueo (Hawaiian short-eared owl), mongooses, cats, rats, dogs, ‘auku‘u (black-crowned night-heron), 

cattle egrets, common mynas, ‘akekeke, laughing gulls, American bullfrogs, and large fish (Robinson 

et al. 1999, Rauzon and Drigot 2002). 

Ae‘o pair © Brian Barker
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

4-8 Chapter 4. Refuge Biology and Habitat

Figure 4.1. Peak counts of ae‘o at Keālia Pond, 1995-2010.

Year 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 4. Refuge Biology and Habitat 4-9 

Figure 4.2 - Ae‘o (Hawaiian Stilt) Nesting Areas
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

4-10 Chapter 4. Refuge Biology and Habitat

To preserve the quality of this figure, this side was left blank intentionally. 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 4. Refuge Biology and Habitat 4-11 

Figure 4.3 - ‘Alae ke‘oke‘o (Hawaiian Coot) Nesting Areas 
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Draft Comprehensive Conservation Plan and Environmental Assessment 

4-12 Chapter 4. Refuge Biology and Habitat

To preserve the quality of this figure, this side was left blank intentionally. 
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Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 4. Refuge Biology and Habitat 4-13 

4.3.2 ‘Alae ke‘oke‘o (Fulica alai) or 

Hawaiian Coot 

The ‘alae ke‘oke‘o is an endangered species 

endemic to the main Hawaiian Islands, except 

Kaho‘olawe, and has occurred sporadically as a 

vagrant to the NWHI, as far west as Kure Atoll. The 

Draft Revised Recovery Plan for Hawaiian 

Waterbirds lists the ‘alae ke‘oke‘o as having high 

potential for recovery and a low degree of threats. 

‘Alae ke‘oke‘o prefer freshwater ponds or wetlands, 

brackish wetlands, and manmade impoundments with open water that is less than 12 inches deep for 

foraging. They favor nesting habitat that has open water with emergent aquatic vegetation or heavy 

stands of grass. Nesting occurs mostly December-March when water partially floods emergent 

vegetation, with opportunistic nesting occurring year-round depending on rainfall (Figure 4.3, 

previous page). ‘Alae ke‘oke‘o will construct floating nests of aquatic vegetation, semi-floating nests 

attached to emergent vegetation, or in clumps of wetland vegetation. ‘Alae ke‘oke‘o feed on seeds 

and vegetative parts of aquatic and terrestrial plants, freshwater snails, crustaceans, tadpoles of 

marine toads, small fish, and aquatic and terrestrial insects (Brisbin et al. 2002). 

Figure 4.4. Peak counts of ‘alae ke‘oke‘o at Keālia Pond, 1995-2010.

‘Alae ke‘oke‘o Laura Beauregard/USFWS

Year 
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Draft Comprehensive Conservation Plan and Environmental Assessment 

4-14 Chapter 4. Refuge Biology and Habitat

The State population has fluctuated between 2,000-4,000 birds with the Maui population fluctuating 

between 200-1,000 birds. Interisland dispersal is most likely influenced by seasonal rainfall patterns, 

wetland condition and food abundance. The highest count of ‘alae ke‘oke‘o at Keālia Pond 

was1,126 birds in 2009 (Figure 4.4). Cats, dogs, and mongooses are the main predators of adult and 

young ‘alae ke‘oke‘o. Other predators include the ‘auku‘u, cattle egret, and large fish. ‘Alae ke‘oke‘o 

are susceptible to avian botulism outbreaks in the Hawaiian Islands (Brisbin et al 2002, USFWS 

2005). 

4.3.3 Koloa maoli (Anas wyvilliana) or Hawaiian Duck 

The koloa maoli is an endangered waterfowl 

endemic to the Hawaiian Islands. The former range 

of the koloa maoli includes all the main Hawaiian 

Islands except Lana‘i and Kaho‘olawe. The current 

Statewide population of pure koloa maoli is 

estimated at 2,200 birds. There is a high degree of 

threat due to hybridization with mallards, the 

greatest threat to this species’ continued existence. 

Birds on O‘ahu and Maui are thought to be 

primarily koloa-mallard hybrids, with estimated 

counts of 300 and 50 birds, respectively. 

In 1989, 12 captive-bred koloa maoli were released on Maui; however, because mallards were not 

removed before the release, hybridization has resulted in more hybrids present on Maui than koloa 

maoli. The population of koloa maoli on Maui is probably fewer than 20 birds. In order for pure 

koloa maoli to successfully breed on Maui, the removal of all hybrids and domestic resident mallards 

in the State will need to occur. Birds on both O‘ahu and Maui are thought to be primarily koloamallard hybrids, with estimated counts of 300 and 50 birds, respectively (Engilis et al. 2002, Hawai‘i 

Audubon 2005, Uyehara et al. 2007). 

The koloa maoli uses lowland wetlands, flooded grasslands, aquaculture ponds, and agricultural 

areas. The Refuge provides suitable habitat for foraging, loafing, pair formation, and breeding. Nests 

are placed in dense shoreline vegetation of small ponds, streams, ditches, and reservoirs. Types of 

vegetation associated with the nesting sites of koloa maoli include fetched and bunch-type grasses, 

rhizominous ferns, and shrubs. The diet consists of aquatic invertebrates, aquatic plants, seeds, 

grains, green algae, aquatic mollusks, crustaceans, and tadpoles (Engilis et al. 2002, USFWS 2005). 

Known predators of eggs and ducklings include mongooses, cattle egrets, cats, dogs; and possibly 

rats and Samoan crabs. ‘Auku‘u and bullfrogs have been observed to take ducklings. Avian diseases 

are another threat to koloa maoli with outbreaks of avian botulism occurring annually throughout the 

State. In 1983, cases of adult and duckling mortality were attributed to aspergillosis and salmonella. 

4.3.4 Nēnē (Branta sandvicensis) or Hawaiian Goose 

The nēnē is a medium-sized goose endemic to the Hawaiian Islands. Adult males and females are 

mostly dark brown or sepia with a black face and crown, cream-colored cheeks, and a buff neck with 

black streaks. Females are smaller than males. Compared to other geese, nēnē are more terrestrial and 

Koloa-mallard hybrids Mike Silbernagle/USFWS
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 4. Refuge Biology and Habitat 4-15 

‘Auku‘u looks for prey Laura Beauregard/USFWS

have longer legs and less webbing between their 

toes. The nēnē was listed as endangered in March 

1967, and is the State bird of Hawai‘i. 

Nēnē historically occurred in lowland dry forests, 

shrublands, grasslands, and montane dry forests and 

shrublands. Habitat preferences of contemporary 

populations are likely biased as preferences may be 

influenced by the location of release sites of captivebred birds. Nēnē can be found from 0-7,900 ft 

(Mitchell et al. 2005, USFWS 2004). 

In 1951, the wild nēnē population was estimated at 30 individuals. All populations since then have 

been or are currently being supplemented by captive-bred birds. As of 2005, the population was 

estimated at between 1,300-1,500 individuals, with 295-325 birds on Maui. Four nēnē were observed 

at Keālia Pond in February 2009, however, they departed after a couple days. Keālia Pond has 

potential habitat for this species, providing forage within the flats north of the main pond. (Mitchell 

et al. 2005). 

Current threats include: predation by mammals; insufficient nutritional resources; a lack of lowland 

habitat; human disturbance; problems related to captive propagation; and inbreeding depression. 

Predators of nēnē eggs and goslings include dogs, cats, rats, and mongooses. Dogs and mongooses 

are also responsible for most of the known cases of adult predation. In recent years, nēnē have been 

struck and killed by golf balls and vehicles (USFWS 2004b). 

4.4 Other Hawaiian Waterbirds 

‘Auku‘u (Nycticorax nycticorax hoactli) 

or Black-crowned Night-heron 

The indigenous ‘auku‘u is a cosmopolitan species 

resident to the main Hawaiian Islands. The blackcrowned night-heron is a species of moderate 

concern in North America; however, ‘auku‘u in 

Hawai‘i are not given this designation. ‘Auku‘u 

feed throughout the Refuge. They breed in kiawe 

trees west of Kanuimanu ponds. 

The ‘auku‘u is known to forage on crustaceans, 

insects, fish, frogs, and mice. They have been observed eating the eggs and young of the endangered 

ae‘o, koloa maoli, and ‘alae ke‘oke‘o. This species may also be a predator of ‘alae ‘ula eggs and 

young. Nesting occurs in colonies in December-May in Hawai‘i. ‘Auku‘u are susceptible to human 

disturbance during nesting (Davis 1993, Mitchell et al. 2005). 

Nēnē Laura Beauregard/USFWS
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Draft Comprehensive Conservation Plan and Environmental Assessment 

4-16 Chapter 4. Refuge Biology and Habitat

4.5 Migratory Waterfowl 

For centuries, migratory ducks, geese, and other waterfowl have wintered in the Hawaiian Islands 

from September-May. Up to 300 koloa mohā (Northern shoveler) and 200 koloa māpu (Northern 

pintail) have been counted at Keālia Pond. Common winter migrants observed at the Refuge include 

green-winged teal, American wigeon, Eurasian wigeon, scaup, and mallard. Migratory mallards do 

not pose the same hybridization threats to koloa maoli as the domestic, resident mallards because 

they rarely breed during their winter stop-overs (Staples & Cowie 2001). 

Statewide surveys in the early 1950s estimated 

wintering populations of up to 8,000 koloa māpu 

and 2,000 koloa mohā. Surveys from the early 

1980s have averaged less than 900 koloa māpu and 

fewer than 800 koloa mohā Statewide. At Keālia 

Pond, koloa māpu numbers fluctuated in the 1950s, 

but peak numbers ranged around 70-80 birds. In the 

last 10 years the counts had a similar range. Peak 

koloa mohā numbers in the 1950s at Keālia Pond 

were 400-600 birds. This number was 100-200 

birds during years 2000-2010. 

Waterfowl use the open waters of the main pond, vegetated wetlands along the pond shoreline, and 

the north ponds where open water is interspersed with emergent vegetation. Impounded wetlands 

provide habitat to a small number of waterfowl. Table 4.4 highlights attibutes, indicators, and 

conditions for Refuge management for waterfowl. Low fall/winter water level below the vegetated 

portion of Keālia Pond would restrict waterfowl populations to impoundments. Invasive pest plant 

species that displace emergent vegetation reduce food and cover. They are susceptible to avian 

botulism. Deterioration of water quality with increased urbanization would impact aquatic 

invertebrates needed by migratory waterfowl for food. 

Table 4.4. Waterfowl Ecological Attributes, Indicators, and Condition Parameters. 

Key Ecological Attributes Indicators Desired Conditions 

Hydrology Water level Water extends into emergent vegetation 

Species abundance Population counts Stable or increasing 

Food availability •Coverage of emergent 

vegetation 

•Abundance of invertebrates 

•Stable or increasing coverage 

•High densities, but below nuisance level 

that affect neighboring communities 

4.6 Migratory Shorebirds 

The Pacific Island Region functions as essential migratory habitat for maintaining global shorebird 

populations. Keālia Pond supports one of the largest populations of migratory shorebirds in Hawai‘i. 

Migration begins in August and most shorebirds leave by April. Abundant migrants include kōlea, 

‘ūlili, ‘akekeke, hunakai, pectoral sandpiper, and dowitcher. Shorebirds frequently use Mā‘alaea 

Flats and the east portion of the main pond, however, the entire Refuge provides shorebird habitat. 

Koloa mohā Michael Walther
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 4. Refuge Biology and Habitat 4-17 

Shorebird numbers have remained relatively stable 

with fluctuations depending on winter water levels. 

Vegetation control in the wetlands has provided 

shallow water habitat during years of high water. 

Shorebirds primarily use unvegetated mudflats, 

wetlands and tidal flats; however, estuaries, 

grasslands, and uplands are also important habitats. 

Grasslands and beaches are important habitats for 

the kōlea and the kioea (bristle-thighed curlew). 

Table 4.5 notes attibutes, indicators, and conditions 

for Refuge management for shorebirds. See Figures 

4.4 and 4.5 for kōlea and ‘ūlili counts.

Table 4.5. Shorebird Ecological Attributes, Indicators, and Condition Parameters 

Key Ecological Attributes Indicators Desired Conditions

Hydrologic Regime •Water level 

•Water coverage 

•1.8 ft MLLW 

•80% coverage

Species abundance •Counts •Stable or increasing

Food availability •Invertebrate density •High density, but below nuisance level

Threats to shorebirds in the Pacific Region include habitat loss, pest plants and animals (predation, 

disease, and competition), human disturbance, and environmental contaminants. The kōlea is the 

most common shorebird in the Pacific Region, with Hawai‘i supporting a substantial portion of the 

Alaskan breeding population during winter. The kioea is the only migratory species that exclusively 

winters in the Pacific. Thus, the Pacific Region is considered to be a critical area for supporting 

hemispheric populations of both these species. Table 4.6 highlights the shorebirds of primary 

conservation importance in the Pacific region (Engilis and Naughton 2004). 

 

Table 4.6. Shorebirds of Primary Conservation Importance in the Pacific Region 

Species Hawai‘i Winter 

Population 

Regional 

Trend 

Conservation Category 

Kōlea 15,000–20,000 Unknown High Concern 

Ae‘o 1,200–1,600 Unknown Highly Imperiled 

Kioea 800 Unknown High Concern 

‘Ūlili 1,000 Unknown Moderate Concern 

‘Akekeke 5,000–7,000 Unknown Low Concern 

Threats specific to Keālia Pond include: fall/winter water level extending to the upper reaches of the 

wetlands; pest plant species encroaching onto unvegetated pond bottom; and deterioration of water 

quality with negative impacts to aquatic invertebrate densities. 

 

‘Akekeke forages during island visit © Michael Walther
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

4-18 Chapter 4. Refuge Biology and Habitat

Figure 4.5. Peak counts of kōlea at Keālia Pond, 1994-2006.

1994/95

1995/96

1996/97

1997/98

1998/99

1999/00

2000/01

2001/02

2002/03

2003/04

2004/05

2005/06

0

200

400

600

800

1000

Figure 4.6. Peak counts of ‘ūlili at Keālia Pond, 1994-2006.

1994/95

1995/96

1996/97

1997/98

1998/99

1999/00

2000/01

2001/02

2002/03

2003/04

2004/05

2005/06

0

10

20

30

40

50

60

70
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 4. Refuge Biology and Habitat 4-19 

4.7 Seabirds 

With the inclusion of the Molokini Unit, nesting habitat for seabirds will be within the Refuge. 

 

4.7.1 ‘Ua‘u kani (Puffinus pacificus) or Wedge-tailed Shearwater

‘Ua‘u kani are widespread throughout the tropical 

and subtropical Pacific and Indian Oceans. There 

are at least four large ‘ua‘u kani nesting colonies 

on Maui. All of these colonies are threatened with 

predation by cats and dogs, seriously decreasing 

fledging success. The dunes adjacent to Mā‘alaea 

Flats has the potential for ‘ua‘u kani nesting and in 

2010 calls were heard but nests were not located. 

The largest colony occurs on Molokini where 

mammalian predators are absent and fledging 

success is high. Adult birds arrive in March to 

reestablish pair bonds and burrowing activity with a 

short hiatus in April before eggs are laid. A 

majority of the burrows appear to be remnants from the previous year’s nesting season and, despite 

the rocky substrate, some burrows extend beyond arms reach. Other burrows are shallow and merely 

situated in rock crevices. In general, one egg is laid in June and hatches in July (incubation averages 

50 days), and parental care is relatively long, lasting up to 31⁄2 months. During nesting, parents share 

duties with incubation and chick rearing (Whittow 1997). 

4.7.2 ‘Ou (Bulweria bulwerii) or Bulwer’s Petrel 

Indigenous to Hawai‘i, ‘ou have long pointed 

wings, a long pointed tail, a black bill and pale short 

legs. They are known to nest in rock crevices on 

Molokini; however, the number of nesting pairs, 

active nests, and fledging success is unknown. It is 

not often seen due to its nocturnal habits and its 

small size makes it particularly vulnerable to 

predation by rats and barn owls on islands where 

these pests have been introduced (Megyesi and 

O’Daniel 1997).

 

Resting ‘ua‘u kani © Michael Walther

‘Ou in rock crevice Eric Vanderwerf /USFWS
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

4-20 Chapter 4. Refuge Biology and Habitat

4.7.3 Noio kōhā (Anous stolidus) or Brown Noddy 

Noio kōhā are medium sized, dark, brown birds. Adults have an 

ashy-white forehead and crown sharply demarcated from black lores, 

merging evenly into gray nape. They have a long, narrow, wedgedshaped tail. The bill is black and stouter than the black noddy and the 

legs and feet are dark brown. Young birds have a more restricted 

white cap on forehead than adults. Noio kōhā are common in the 

NWHI, and also nest on several of the offshore islets. They typically 

remain near their breeding colonies year-round. Noio kōhā feed by 

diving for small fish. They often prey on the same fish as aku 

(skipjack tuna), and can be used to find tuna schools, leading to the 

common name “aku bird” (Chardine 1996, Berger 1972). 

4.7.4 Noio (Anous minutus) or Black Noddy 

Noio resemble the closely-related noio kōhā, but are smaller with 

darker plumage, a whiter cap, a longer, thinner bill and shorter tail. 

Noio nest from March-August on ledges of coastal cliffs and caves 

of the main islands and on several offshore islets. Nests are usually 

located in sea caves or on high ledges. One egg is laid each season, 

and nests are re-used in subsequent years. Chicks usually fledge in 5 

- 7 weeks, although rearing of individual chicks may be prolonged 

during periods of low prey availability (Flint 1999). 

4.7.5 ‘Iwa (Fregata minor) or Great Frigatebird

‘Iwa roost on several of the offshore islets, including Lehua, 

Mokumanu, and Molokini, and can be seen flying high in the sky 

almost anywhere in the main islands, but they are not known to nest 

on any of them. ‘Iwa feet, like many seabirds, are located more 

posteriorly than land birds which makes walking difficult, but in the 

air they are graceful and acrobatic. ‘Iwa means “thief” in Hawaiian 

and as their name suggests, they obtain food by piracy, chasing down 

other seabirds and forcing them to relinquish their catch (Flint 1999). 

Soaring ‘iwa USFWS 

Noio Glen Fergus/USFWS

Noio kōhā USFWS
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 4. Refuge Biology and Habitat 4-21 

Pueo © Tom Dove

 ‘Īlio-holo-i-ka-uaua rests on beach 

© Jim Collin/ AP

4.8 Raptors 

Pueo (Asio flammeus sandwichensis) or Hawaiian 

Short-eared Owl 

Unlike most owls, pueo are diurnal and are occasionally seen 

hovering or soaring over open areas. Like short-eared owls in 

continental environments, those in Hawai‘i primarily consume small 

rodents, insects, and rarely, birds. The Refuge offers breeding and 

foraging habitat for the pueo, although no nesting has been 

documented to date. Males perform aerial displays known as a sky 

dancing display to prospective females. 

Found on all the main Hawaiian Islands from 0-8,000 feet, pueo are 

likely susceptible to the same factors that threaten other native birds, 

including loss and degradation of habitat, predation by introduced 

mammals, and disease. 

4.9 Endangered Mammals 

‘Īlio-holo-i-ka-uaua (Monachus schauinslandi) or 

Hawaiian Monk Seal 

‘Īlio-holo-i-ka-uaua are among the most critically endangered 

mammals in the world. Only about 1,200 seals are alive today. Most 

seals live in the NWHI, but there is a small and potentially growing 

population of seals in the main Hawaiian Islands where a 2005 

survey observed 76 individuals. 

Its Hawaiian name means “the dog that runs in the rough seas.” 

They frequently haul out on shorelines to rest and molt. Females 

also haul out on shore for up to 7 weeks to give birth and nurse their 

pups. Pups and moms stay ashore until weaned. Mating occurs in 

the spring and early summer. Gestation is approximately 1 year. 

Pupping occurs in late winter and spring. ‘Īlio-holo-i-ka-uaua can 

live to 25 years of age. 

They feed on reef fishes, he‘e (octopus), squid, and lobsters down to 

depths of 1,000 feet. Juveniles feed on a higher proportion of nocturnal fish species. Food seems to 

be a limiting factor for population growth at this time. Terrestrial habitat is used about one-third of 

the time and requirements there include haul out areas for pupping, nursing, and resting, primarily on 

sandy beaches, but virtually all substrates are used. Beachside vegetation is used for protection from 

wind and rain. 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

4-22 Chapter 4. Refuge Biology and Habitat

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

significant in the main Hawaiian Islands. Dogs have attacked ‘īlio-holo-i-ka-uaua, and they carry 

diseases that are potentially lethal to ‘īlio-holo-i-ka-uaua. Human disturbance, especially of mothers 

with pups, may be a threat at the Refuge. 

4.10 Terrestrial Invertebrates 

‘Ōka‘i ‘aiea (Manduca blackburni) or Blackburn’s Sphinx Moth 

The ‘ōka‘i ‘aiea is one of Hawaii’s largest native insects with a wing span of up to 5 inches. Adults 

are overall gray with black bands across the top of their wings and five orange spots on each side of 

their abdomen. Caterpillars are large and populations contain two color morphs, bright green or gray. 

Both morphs have scattered white speckles across their back and a horizontal white stripe on the side 

of each segment. Caterpillars feed on plants in the nightshade family (Solanaceae), especially native 

trees in the genus Nothocestrum, but also on non-native solanacious plants such as commercial 

tobacco, tree tobacco, eggplant, tomato, and Jimson weed. Adults have been observed feeding on the 

nectar of koaliawa. The dry upland forest provides habitat potentially suitable habitat for the ‘ōka‘i 

‘aiea. 

Believed to be extinct in the late 1970s, the species

was rediscovered in 1984 on East Maui. Additional 

populations recently have been found on Kaho‘olawe 

and the island of Hawai‘i. Historically, the species 

likely occurred on Kaua‘i, O‘ahu, and Moloka‘i as 

well. ‘Ōka‘i ‘aiea can be found across a broad 

elevational gradient from 0-5,000 ft. This native 

Hawaiian moth was the first Hawaiian insect to be 

added to the endangered species list. The Service is 

currently funding research examining its life history, 

captive rearing, and conservation biology (USFWS 

2003). 

4.11 Aquatic Invertebrates 

Aquatic invertebrates are present in all wetland habitats with more species diversity in palustrine 

wetlands. Midges are seasonally abundant in all wetlants except Mā‘alaea Flats and water boatmen 

are abundant in all habitats yearround. Midges were quantitatively sampled in 1997 and the first 

monitoring began the following year when Keālia Pond had a density of 993 midge larvae/yd2

. A 

large emergence occurred in 2000 when densities of 25,977 larvae/yd2

 were recorded. Monitoring 

showed a relationship between partial drying of the main pond and the pond filling the following 

winter. Water boatmen received less attention since they do not create a nuisance to nearby 

residents. However, in 2007 the Refuge recorded a maximum of 48,462 water boatmen/yd2

. 

Inventories of other invertebrates included 92 families of both terrestrial and aquatic species. Five 

aquatic invertebrate families commonly occur in the main pond (Wirwa 2007). 

‘Ōka‘i ‘aiea © James Bruch, KIRC
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 4. Refuge Biology and Habitat 4-23 

4.12 Marine Reptiles 

4.12.1 Honu ‘ea (Eretmochelys imbricata) or Hawksbill Turtle 

The endangered honu ‘ea, or just ‘ea, is one of the smaller sea turtles and takes its species name 

(imbricata) from the overlapping plates on its upper shell and its common name from the shape of its 

hooked jaw. The carapace (top shell) of an adult ranges from 25-35 inches in length and has a 

"tortoiseshell" coloring, ranging from dark to golden brown, with streaks of orange, red, and/or 

black. 

Honu ‘ea use different habitats at different stages of their life cycle, but are typically found around 

coastal reefs, rocky areas, estuaries, and lagoons. Its narrow head and jaws shaped like a beak allow 

it to get food from crevices in coral reefs. They eat sponges, anemones, squid and shrimp. At night, 

from May-October, mature females (20-50 years old) crawl ashore and excavate chambers above the 

high-tide line, in which they lay their eggs. In 7-10 weeks the eggs hatch and the tiny hatchlings 

make their way to the surface and out to sea (Perrine 2003). 

4.12.2 Honu (Chelonia mydas) or Hawaiian Green Turtle 

The Hawaiian honu is listed as threatened under the ESA . Marine debris can prove deadly when it 

entangles honu or is mistaken for food and ingested. Plastics are particularly harmful as they may 

remain in the honu’s stomach for long periods of time, releasing toxic substances, and can clog the 

digestive system. Noise, lights, and beach obstructions are disruptive to nesting areas. Rats, 

mongooses, and dogs prey on the eggs (Perrine 2003). 

Little information exists on the feeding behavior of post-hatchlings and juveniles living in pelagic 

habitats, but most likely they are exclusively carnivorous (e.g., soft-bodied invertebrates, jellyfish, 

and fish eggs). Subadult and adult turtles residing in nearshore benthic environments are almost 

completely herbivorous; feeding primarily on limu (algae) and sea grasses. 

The name “green sea turtle” is derived from the color of their body fat, which is green from the limu 

they eat. Adult honu can weigh up to 500 pounds and are often found living near coral reefs and 

rocky shorelines. Hawaiian honu grow slowly compared to other populations, with an average annual 

Honu ‘ea Caroline Rogers/USGS Honu Laura Beauregard/USFWS
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

4-24 Chapter 4. Refuge Biology and Habitat

growth rate of approximately 1⁄2-2 inches. Turtles often reach sexual maturity at 35-40 years of age 

(Gardner 1996). 

Females may lay up to 6 clutches per season, with each cluth containing about 100 eggs. Evidence 

shows that Hawaiian honu only migrate throughout the 1,500-mile expanse of the Hawaiian 

Archipelago, and so make up a discrete population. Hatchlings and juveniles live in pelagic waters. A 

majority migrate to French Frigate Shoals for nesting; however, within the past decade, there has 

been an increase in number of honu nesting on the main Hawaiian Islands. There are a few periodic 

reports of nesting honu on Maui prior to 2000 but it wasn’t until that year when a female nested 

regularly (every 2 years) until 2008. Between 2000 and 2010, there has been at least one female 

nesting on Maui. 

The same threats face honu as the honu ‘ea. Sea 

Turtle Dawn Patrol volunteers conduct early 

morning walks on Mā‘alaea Beach from JuneSeptember to look for turtle tracks from the previous 

night. Once observed, they contact the Refuge or the 

Division of Aquatic Resources who are partners in 

the Maui sea turtle monitoring program. Through 

this program, researchers collect information on 

clutch size, hatching and emergence success, and 

genetics. 

Honu and honu ‘ea crawling ashore to nest suffer fatalities when they start crossing roads. This 

occurred twice (1993 and 1996) when females were hit and more recently in 2009 when hatchlings 

emerging from nests next to the North and South Kihei Roads were attracted to lights on the other 

side and were run over. These fatalities on a critically endangered species prompted the Service to 

collaborate with landowners, A&B Properties, to install a fence within the coastal strand parallel with 

N. Kihei Rd. The Refuge maintains the turtle fencing along the coastal strand to prevent turtles from 

entering onto the road.

4.13 Native Plants 

Native Hawaiian plants arrived to the archipelago via natural means such as wind, water, or birds. 

According to Wagner et al. (1999), the native Hawaiian flora is comprised of roughly 956 species 

within 87 families. Approximately 89 percent of these species are endemic (found only in Hawai‘i), 

while the remainder are indigenous (naturally found in Hawai‘i and elsewhere). Since their 

establishment, populations of Hawai‘i’s native vegetation have greatly declined. Few native plants 

have escaped the impacts of urbanization and agriculture on the coastal and lowland habitats. Coastal 

alterations such as agriculture, residential developments, recreational parks, military installations, 

golf courses, and roads, have permanently displaced much of the native flora. With potential 

expansion of the Refuge at Mā‘alaea Flats and Molokini, protection and outplanting will improve the 

native plant diversity and distribution (Cuddihy and Stone 1994). 

Although the Refuge was designed to protect waterbirds, native plant species do occur. Several 

restoration efforts have contributed to native plant populations. Native species planted include 

‘aki‘aki, ‘akulikuli, kaluhā, naio papa, ulei, naupaka, akia, and makaloa. 

Turtle fencing along the coastal strand USFWS
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 4. Refuge Biology and Habitat 4-25 

‘Ihi with buffel grass nearby © Forest & Kim Starr

A 2006 botanical survey of Maui’s offshore islets included a visit to Molokini. Native species 

pā‘ūohi‘iaka (Jacquemontia ovalifolia) and ‘ilima (Sida fallax) were found scattered about the islet. 

It was noted that the diversity of plants increased in open areas not dominated by invasive buffel 

grass. Along the lower portions of the islet, close to the ocean, ‘ena ‘ena, ‘akulikuli, ‘ōhelo kai, and 

‘ihi wwere found. Of the 35 plant species observed during the survey, 9 (26%) were native and 26 

(74%) were non-native. 

‘Ihi (Portulaca molokiniensis) 

The extremely rare coastal ‘ihi grows on volcanic tuff on Molokini. It is a low-lying herb with thick, 

fleshy green leaves and small, bright yellow flowers. Federally listed as a species of concern, ‘ihi is 

currently found in low numbers on Molokini, ‘Ale‘ale, and Pu‘ukoa‘e Islets; as well as the Island of 

Kaho‘olawe. 

It was first collected in 1913 by Charles Forbes who 

identified it as Portulaca aff. lutea. Robert Hobdy 

described it as a distinctly new species, Portulaca 

molokiniensis, in 1982, noting that it differs from P. 

lutea “in its conspicuous vegetative growth and 

larger leaves, and especially in its dense head-like 

clusters of flowers and spinose seeds.” During the 

2006 botanical survey, ‘ihi was observed in a thicket 

of buffel grass. Restoration plans include carefully 

removing nearby pest grasses, allowing the ‘ihi to 

spread. Additional plants could be propagated 

through seeds or cuttings and out-planted in areas 

free of buffel grass. 

4.14 Invasive Species 

For the purpose of this CCP, an invasive species is defined as a species whose migration and growth 

within a new range is causing detrimental effects on the native biota in that range. Mammals, 

amphibians, invertebrates, and plants can all be considered invasive. These species become invasive 

because their population and growth are no longer balanced by natural predators or biological 

processes that kept them in balance in their native ecosystems. In the absence of these restraints, 

invasive species have the potential to compete with native species for limited resources, alter or 

destroy habitats, shift ecological relationships, and transmit diseases. Native species as well as nonnative species can become invasive when their natural ecosystem is out of balance. 

Invasive species are one of the most serious problems in conserving and managing natural resources. 

In particular, the ecological integrity of Pacific Island environments is greatly threatened by invasive 

species. Hawai‘i, which existed in isolation for millions of years, is an exceptionally ideal 

environment for these species. Most native species lost their natural defense mechanisms and are 

more vulnerable to introduced species (Pattison et al. 1998, Ikuma et al. 2002, Middleton 2006). 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

4-26 Chapter 4. Refuge Biology and Habitat

4.14.1 Mammals

Rat (Rattus spp.)

Three pest rat species are found throughout the 

Hawaiian Islands. Polynesian rats arrived from the 

central Pacific 1,500 years ago with the Polynesians; 

Norway rats reached the Hawaiian Islands after the 

arrival of Captain Cook in the 1770s; and black rats 

most likely arrived in the 1870s. It is estimated that 

these three species have populated nearly 82 percent 

of the major islands. 

Black and Polynesian rats can be found from 0-

10,000 feet. Norway rats are restricted to areas 

below 6,000 feet. Polynesian rats and Norway rats 

nest exclusively in terrestrial habitats, while black rats are arboreal nesters. This nesting difference 

may contribute to a larger population of black rats in Hawai‘i due to the presence of non-arboreal 

mongoose predators (Tobin and Sugihara 1992, Hays and Conant 2007). 

All three species in Hawai‘i are known predators of eggs, nestlings, young, and occasionally adults 

of endangered waterbirds, seabirds, migratory shorebirds, and forest birds. Ground- and burrownesting seabirds are particularly vulnerable to rat predation, even by the arboreal black rat. Rats also 

consume plants, insects, mollusks, herpetofauna, and other invertebrates. Because these prey species 

are also eaten by birds, a reduction in these populations may indirectly affect avian populations 

(Olson and James 1982, Harrison et al. 1984, Brisbin et al. 2002, Engilis et al. 2002, Mitchell et al. 

2005). 

The use of snap traps and ground-based application of diphacinone rodenticide to control rats in the 

main Hawaiian Islands has shown a positive effect in native bird survival. Rat control is conducted 

year-round near public use areas at Keālia Pond NWR with various methods including the use of live 

traps, and snap traps. 

Small Indian mongoose (Herpestes javanicus) 

The small Indian mongoose was intentionally introduced to numerous island ecosystems during the 

1800 and 1900s and has since expanded to large portions of Asia, Africa, Europe, Oceania, and the 

Americas. In 1883, the species was introduced to the main Hawaiian Islands as a biocontrol agent 

against rats in sugarcane fields. The mongoose 

inhabits all habitat types from 0-10,000 feet on the 

islands of Hawai‘i, Maui, O‘ahu, and Moloka‘i. In 

other areas of the world, mongooses appear to avoid 

wet areas; however, in Hawai‘i, dense populations 

of mongooses are concentrated in wet habitats. 

The home range of a female in Hawai‘i is about 3.5 

acres, and the main reproductive period occurs from 

February-August. The high density of mongooses in 

the Hawaiian Islands is due to abundant food and 

Black rat © Jack Jeffrey

Mongoose on the prowl © Chuck Babbitt 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 4. Refuge Biology and Habitat 4-27 

the lack of natural predators. They are voracious omnivores, consuming insects, reptiles, mammals, 

amphibians, crabs, plants, and birds. In Hawai‘i, mongooses are diurnal predators that primarily eat 

invertebrates and secondly small mammals. They are a major threat to any ground-dwelling and -

nesting species in Hawai‘i. These mammals are known to eat eggs, young, and adults of endangered 

waterbirds, seabirds, and shorebirds. In addition, mongooses are known to consume young honu 

(Tomich 1986, Staples and Cowie 2001, Mitchell et al. 2005, Hays and Conant 2007). 

Mongoose populations have been managed at the refuge since 1996 using traps near waterbird 

nesting areas during breeding seasons. 

Cat (Felis catus) 

Cats arrived in Hawai‘i in the early 1800s on 

European ships and are now found on all the main 

Hawaiian Islands from 0-10,000 feet. They are 

frequently observed on the Refuge and are 

occasionally caught in our trapping program. 

Cats are natural hunters with their sharp teeth; the 

upper teeth overlap the lower, giving them a firm 

grasp to shake or tear prey to death. Food habits of 

cats in Hawai‘i include insects, centipedes, 

crustaceans, lizards, mice, rats, bird eggs, and birds 

(Scott and Thomas 2000, Mitchell et al. 2005). 

Dog (Canis lupus familiaris)

The dog is a domesticated form of the gray wolf, a member of the Canidae family of the order 

Carnivora. Abandoned, escaped, or pet dogs allowed to run loose can cause great harm to native 

species and ecosystems. Dogs have caused terrible damage to native ground-nesting seabird colonies. 

Dogs typically attack a large number of birds in a single incident by grabbing and shaking the birds 

around with their mouths and leaving them for dead before heading to another nest or burrow. 

Axis Deer (Axis axis)

Axis deer originate from India and are also known as cheetal deer. Its coat is reddish fawn, marked 

with white spots, and its underparts are white. It stands about 3 ft tall at the shoulder and masses 

about 185 lb. Its lifespan is around 20-30 years. It has a protracted breeding season due in part to the 

tropical climate, and births can occur throughout the year. For this reason, males do not have their 

antler cycles in synchrony and there are some fertile females at all times of the year. In 1959, nine 

deer were introduced to Maui by the Territorial Legislature for increased hunting opportunities and to 

provide subsistence for island residents. In 1968, the Maui population was estimated to be 85-90 

animals. Today, reports of deer sightings occur throughout Maui from Hāna to Kapalua with 

numbers estimated in the thousands island-wide. The growing population of axis deer has created a 

number of concerns ranging from vehicle accidents, poaching, ecosystem damage, and disease to 

crop damage (Maui Axis Deer Group 2002). 

Neutered and released cat with ‘alae ‘ula 

© Michael Walther
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

4-28 Chapter 4. Refuge Biology and Habitat

4.14.2 Birds 

There are a number of non-native species that have been introduced through human activity. Maui’s 

native birds coevolved in isolation and developed specialized life history requirements in order to 

minimize competition. Most of the non-native birds have been introduced just within the last 100 

years and use the same habitats, eat the same foods, and use similar foraging strategies as our native 

birds. Direct competition for limited food and habitat may be a serious issue. These species are 

resistant to avian pox and malaria and may serve as carriers for transmitting these devastating 

diseases. 

Non-native bird species are fairly common to abundant, and also 

play a role in spreading the seeds of invasive plants into native 

habitats. More study is needed and close monitoring is critical. One 

of the non-native birds identified as a pest species is the cattle egret. 

Cattle egret (Bubulcus ibis) 

The cattle egret was introduced to Hawai‘i in 1959 from Florida for 

insect control on cattle and has become widespread. Rookeries 

were documented on Ni‘ihau, Kaua‘i, O‘ahu, Hawai‘i Island, 

Moloka‘i, Lana‘i, and Maui by the mid-1980s. Cattle egrets were 

known to roost and nest in stands of red mangrove (now removed) 

east of Kanuimanu ponds and in kiawe adjacent to the access road 

to those ponds. 

Its diet primarily consists of grasshoppers, crickets, spiders, flies, 

frogs, and nocturnal moths, but the bird will also consume prawns, 

mice, crayfish, and the young of native waterbirds. Cattle egrets 

have been documented taking chicks of all endangered waterbirds 

species occurring on the Refuge. If numbers increase and predation 

on endangered waterbirds exceeds our target limit, population control measures identified in the IPM 

are implemented (Brisbin et al. 2002, Engilis et al. 2002, Hawai‘i Audubon Society 2005). 

4.14.3 Amphibians

Cane toad (Bufo marinus) 

Cane toads or Pacific giant toads, which are native 

to Latin America, have a broad geographic range 

that includes a majority of the Pacific region. The 

toads were brought to the Hawaiian Islands in 1932 

to control insect pests. The adults only require water 

for breeding, an event which results in thousands of 

eggs per mating occurrence. Cane toads are active 

at night and primarily feed on cockroaches, crickets, 

grasshoppers, grubs, earthworms, slugs, spiders, 

centipedes, and snails. In addition, these highly invasive amphibians could be a potential predator of 

endangered waterbird eggs and young (Yamamoto and Tagawa 2000, Staples and Cowie 2001). 

Cane toad Laura Beauregard/USFWS

Cattle egret 

Laura Beauregard/USFWS
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Chapter 4. Refuge Biology and Habitat 4-29 

4.14.4 Invertebrates 

Although the Hawaiian Islands support a large number of native invertebrates, wide arrays of pest 

invertebrates have invaded marine and freshwater habitats. 

Spotted-winged midge (Polypedilum nubifer) 

A common, widely-distributed insect in tropical and subtropical waters, the spotted-winged midge is 

a non-native aquatic invertebrate that was first identified on O‘ahu in the 1940s. It is unknown when 

the species first appeared on Maui but accounts from lifetime residents indicate that they existed on 

Maui long before initially identified in 1997 by Bishop Museum when the nuisance issue arose. This 

midge species’ life history is comprised of a larvae form in the upper layer of the pond sediment and 

a flying adult. Larval midge pass through four instars (or phases) with individuals increasing in size 

with successive instars. Larvae are present in the top aerobic layer of pond sediment where they feed 

on detritus and algae. At the completion of the fourth instar, the midge larvae undergoes a 

metamorphosis, travels up through the water column and emerges as a flying insect. Upon 

emergence, the adult’s objective is to mate, lay eggs, and die. A common behavior during this period 

is for adults to congregate, or swarm, increasing their changes to find the opposite sex. When the 

weather is calm, this behavior can be seen from a distance – a black column that can rise to great 

heights. Adults are not strong flyers and are attracted to light sources (and thus the nuisance aspect 

for neighboring condominium residents). The exact life span of the adult form is unknown; however, 

it is expected to be relatively short with the primary objective of reproduction. Once eggs are laid the 

adults die. Egg capsules will attach to vegetation, or any structure in the pond, or are observed 

floating on the water surface. Upon hatching, the first instar larvae move down through the water 

column to the pond sediment and the cycle continues. The larvae to adult cycle is approximately 3 

weeks, plus or minus a few days. 

Midges are important in the diets of endangered waterbirds and are not considered a pest for the 

recovery of the endangered Hawaiian waterbirds. At Keālia Pond, the spotted-winged midge has 

received the attention of nearby residents when there are more than sufficient populations of midges 

to support waterbirds and swarms are attracted to artificial light sources. Therefore, to reduce 

impacts to adjacent residences, a variety of studies have been conducted since 2000 to moderate large 

emergences through habitat manipulation. Several insecticides were tested during this period and 

methoprene, an insect growth regulator, was found to provide relief to adjacent residents. There are 

no other products with similar results so its application must to be carefully monitored to reduce the 

potential that midges would become resistant to it. Recent observations show promise that 

moderately low water level during the winter months reduces midge production below nuisance 

levels. 

Ants 

Hawai‘i is one of the few places on Earth believed to harbor no native ant species. Today, at least 47 

ant species in 7 subfamilies and 24 genera have become established. Ants are a growing concern 

since they can have negative effects on native and endangered plants and animals. Ants are known to 

attack, injure, or kill young birds. Ants are also implicated in having negative effects on native and 

endangered plants. Control of ants has potential on the Refuge to protect trust resources. The Service 

is currently studying the efficacy of various baits and approved toxins on pest ants on O‘ahu and 

Johnston Atoll. It is anticipated that the Refuge will adopt IPM methods to control ants based on the 

results of these studies.
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

4-30 Chapter 4. Refuge Biology and Habitat

4.14.5 Plants 

At the ecosystem level, invasive plants have been shown to be capable of changing fire regimes, 

altering nutrient cycling patterns, and modifying the surface runoff of water. Non-native plants can 

physically displace native species, and/or supersede them in competition for water, nutrients, or other 

limited resources. They can provide habitat for pest animals such as rookeries for cattle egrets in 

stands of kiawe or red mangrove. They can also be vectors and hosts for introduced pests and 

diseases to which the native species lack natural defenses. Almost half the flora of the Hawaiian 

Islands is comprised of naturalized non-native plants, approximately 1,100 species. According to 

Staples and Cowie (2001), invasive plants in Hawai‘i share the following biological and reproductive 

characteristics: 

 Adaptable to and capable of thriving in different habitats; 

 Tolerant of variable conditions (such as light, temperature, moisture); 

 Fast growing; 

 Tolerant of disturbance; 

 Easily dispersible to new localities by seeds, fruits, spores, or vegetative parts; 

 Produce small seeds/spores early in life; 

 Long reproductive periods; and 

 Dispersed by animals and with no special germination requirements. 

The control and eradication of pest plants has been the top priority of natural resource managers in 

Hawai‘i. In the wetland habitats of the Refuge, invasive plant species can drastically reduce the value 

of wetland habitat to native species. Pest species outcompete more desirable plant species here, as 

well as invade open water and mudflat habitats. In addition, the high biomass characteristic of 

invasive grasses produces a high amount of fuel for fire. A combination of IPM techniques are 

employed at Keālia Pond including chemical, mechanical (hand and tractor), prescribed burns, and 

water level manipulations. Restoration efforts are continuous. Pest plants on the Refuge include 

California grass, California bulrush, Indian marsh fleabane, kiawe, Mexican fan palms, red 

mangrove, and the large acreage of pickleweed covering the mudflats. 

Pest plants targeted for removal on Molokini include buffel grass, golden crown beard, sourbush, 

Indian marsh fleabane, koa haole, and sandbur.

California grass (Brachiaria mutica) 

California grass is a sprawling perennial with culms 

up to 19 feet long. Stolons and leaf sheaths are 

densely hairy. It is suspected to have originated in 

sub-Saharan Africa and occurs pantropically as a 

pasture grass. California grass occurs in aquatic 

environments and is reported to be well adapted to a 

wide range of soil conditions (sandy to clay). It 

tolerates moderate shade but prefers full sun (Cook 

et al. 2005). 

It grows prolifically in wetland habitats, but it can also withstand severe drought. In addition to 

displacing native plants, California grass alters and destroys aquatic environments, causing a 

reduction in bird habitat. The grass also interferes with stream flow and poses a nuisance to marine 

California grass Mike Silbernagle/USFWS
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 4. Refuge Biology and Habitat 4-31 

navigation when rafts of the grass float out to sea. The Hawai‘i-Pacific Weed Risk Assessment, 

conducted by UH and the U.S. Forest Service, identifies California grass as “documented to cause 

significant ecological or economic harm in Hawai‘i” (Stone et al. 1992, Motooka et al. 2003). 

Indian marsh fleabane (Pluchea indica) 

Indian fleabane is an erect shrub that grows up to 

6.6 feet tall. It is native to temperate and tropical 

Asia and northern Australia and is naturalized 

elsewhere. In Hawai‘i, it occurs in lowland, coastal 

habitats such as wetlands and fishponds. Initially 

recorded on O‘ahu in 1915, Indian fleabane has 

been identified on Maui, O‘ahu, Kaua‘i, and 

Ni‘ihau. It prefers marshes and saline soils 

(Motooka et al. 2003, GRIN on-line database). 

Indian fleabane will out-compete native sedges on 

the Refuge, reducing forage and nesting habitats for birds. It tends to harbor huge nests of paper 

wasps, which are a hazard to Refuge staff and the public. The Refuge uses mechanical and chemical 

techniques to control this pest species. 

California bulrush (Schoenoplectus 

californicus) 

California bulrush is a perennial sedge found in 

marshy areas from southern and western North 

America to South America. It has tall, thin, dark 

green stems which are usually triangular in crosssection and woolly, bristly tan or brown flowers in 

panicle inflorescences. It has characteristics 

common in the sedge family, such as creeping. It is 

intolerant of shade, but can spread rapidly by 

vegetative means (Wagner et al. 1999, NRCS 2008).

Pickleweed (Batis maritima) 

Pickleweed, native to tropical and subtropical 

America and the Galápagos Islands, is a maritime 

shrub that grows up to 2-3 ft long. The stems are 

cylindrical succulent, with small succulent leaves 

and tiny green flowers. The fruit is red, and is 

spread by floating across the water surface. 

Extremely invasive, pickleweed grows so thickly 

that it can prevent young birds from moving 

between Refuge ponds in attempts to gain access to 

foraging areas. In a 2004 partnership with Ducks 

Unlimited, levees were built up and widened to 

prevent flooding. Slopes were formed to provide 

Pluchea indica Mike Silbernagle/USFWS

California bulrush Mike Silbernagle/USFWS

Pickweed at Kanuimanu ponds USFWS
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

4-32 Chapter 4. Refuge Biology and Habitat

shallow water when ponds were full. Prior to the work, all pickleweed plants were removed and 

Refuge volunteers have out-planted native vegetation on the levee slopes. Pickleweed is also an ongoing pest species in the mudflats. 

Red mangrove (Rhizophora mangle)

The red mangrove is native to tropical America and 

was introduced to Moloka„i in 1902 for erosion 

control. It is found on six of the main Hawaiian 

Islands and forms dense, monospecific thickets 

that will overtake fringing reefs and tidal strand, 

saltwater wetlands, and other riparian habitats. Red 

mangroves grow on prop roots, which arch above 

the water level. Propagules become fully mature 

plants before dropping off the parent tree. These are 

dispersed by water until eventually embedding in 

the shallows. 

Red mangroves have posed a problem since the Refuge was 

established. One restoration project addressed an old stand of trees 

that were so dense that nothing grew under its canopy and it served 

as a rookery for cattle egrets that pose a threat to nesting waterbirds. 

When the mangrove was removed, the native sedge kaluhā spread 

and established in its place. 

Mexican fan palm (Washingtonia robusta) 

Native to Mexican desert washes where underground water is 

continuously available, the Mexican fan palm was introduced as a 

landscape ornamental. It has naturalized in Hawai„i to become 

invasive in disturbed areas. This palm is known to create 

monospecific stands in riparian areas where the water helps disperse 

its seeds. Dead fronds of the tree can create a fire hazard. The easiest 

way to control the species is by 

removing the seedlings (Starr et al. 

2003).

Kiawe (Prosopis pallida) 

Kiawe is native to Peru, Colombia, and Ecuador. Over 150,000 

acres of kiawe forests in Hawai„i are descended from a single tree 

planted in 1828 by Father Bachelot, the first Catholic priest in the 

Hawaiian Islands. By 1840, progeny of the tree had spread to dry, 

leeward plains on all of the islands. Most kiawe have thorns with 

strong, 1-inch long spines. It usually flowers January-March, but in 

years with wet summers it also flowers September-October. The 

small flowers are borne in pale yellow spikes 3-4 inches long and 1⁄2 

inch in diameter (Nelson and Wheeler 1963). 

On windy or dry sites, kiawe grows as a shrub or small, twisted tree 

only 10-16 feet tall. Kiawe was considered a valuable tree for a 

Red mangrove roots Steve Hillebrand/USFWS

Invasive Mexican fan palm 

Jason Hanley/USFWS

Kiawe thorns & seed pods F & K Starr
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 4. Refuge Biology and Habitat 4-33

variety of reasons: its pods and seed are nutritious fodder; a small honey industry depends on kiawe 

flowers; the wood is is used directly for fuel and is also made into charcoal; and, the heartwood is 

durable and preferred for fence posts (Felker et al. 1981). 

Kiawe overshadows native plants and its deep taproots use all 

available water. Dense kiawe thickets have replaced native plants in 

the coastal dry forest at Keālia Pond NWR. 

Buffel grass (Cenchrus ciliaris) 

Most native plants on Molokini are observed in open areas where 

there is a break in the buffel grass, a species native to Africa, Asia, 

Iran, and the extreme south of Europe. It is a perennial grass 

growing to 20 inches tall. It spreads very quickly and will often kill 

native plants by taking away nearby water. Removal of buffel grass 

is the primary management action needed to restore the habitat for 

native plant species on Molokini (Starr et al. 2003).

4.14.6 Diseases 

Avian botulism 

Avian botulism is a paralytic disease caused by ingestion of a toxin produced by the bacteria, 

Clostridium botulinum. This bacteria is widespread in soil and requires warm temperatures, a protein 

source and an anaerobic (no oxygen) environment in order to become active and produce toxin. 

Decomposing vegetation and invertebrates combined with warm temperatures can provide ideal 

conditions for the botulism bacteria to activate and produce toxin. 

Birds either ingest the toxin directly or may eat invertebrates (e.g., chironomids, fly larvae) 

containing the toxin. Invertebrates are not affected by the toxin and store it in their body. A cycle 

develops in a botulism outbreak when fly larvae (maggots), feed on animal carcasses and ingest 

toxin. Ducks that consume toxin-laden maggots can develop botulism after eating as few as 3 or 4 

maggots. Outbreaks can occur most anytime on the Refuge, but typically occur during the summer 

months during warm to hot weather. Thousands of birds have been know to die during a single 

outbreak in areas of high waterfowl concentrations. In Hawai„i there is no seasonal pattern to this 

disease. 

Botulism is one of the few wildlife diseases we can actually manage effectively. Although we do not 

know all the environmental triggers that cause Clostridium botulinum to start producing toxin, we do 

know that if mortalities are detected early enough, certain management techniques, if implemented 

quickly, can rapidly stop and mitigate the magnitude of waterbird mortality. Because animal 

carcasses are an excellent source of protein, removing them reduces the potential for spreading. 

Draining or flooding the wetland can change the environmental conditions sufficiently so as to stop 

the production of toxin. The Refuge experienced a large outbreak in 1999 that prompted a standard 

protocol to check areas for dead birds, especially when water starts receding or if a carcass is found. 

In the event weak birds are found, the Refuge sets up a rehabilitation area to care for birds until they 

show signs of recovery. Birds are released in “clean” (no incidents of botulism) wetlands on Maui 

(with permission). Unfortunately, recovered birds do not become immune to botulism and remain 

susceptible (USGS 2007). 

Buffel grass © F & K Starr
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Mā‘alaea beach strand Laura Beauregard/USFWS

Fibropapilloma tumor disease 

Fibropapillomatosis (FP) of marine turtles is a debilitating neoplastic disease with a global 

distribution that was originally described in honu in Hawai‘i in 1958. The prevalence in certain 

coastal habitats has increased or remained high since systematic surveys were started in the early 

1980s. These tumors can result in debilitation and even death to individual animals. Refuge staff and 

Sea Turtle Dawn Patrol volunteers monitor the frequency and severity of FP occurring on honu 

observed along the shoreline. These observations are reported to the National Marine Fisheries 

Service. Research continues as to the cause and potential future remedies for this disease (Herbst 

1994, Balazs 1991). 

4.15 Habitats 

4.15.1 Coastal Dune/Beach Strand 

Coastal habitats are lands between 0-985 feet in 

elevation that are typically vegetated with strand 

species. The area paralleling the shoreline, also 

referred to as the beach strand, includes beaches, 

coastal dunes, and the zone immediately inland of 

the dunes. Beaches are the most seaward portion of 

the coastal region and are composed of sand or 

other loose materials that are constantly exposed to 

waves and tides. 

Coastal dunes are ridges or mounds of sand located immediately landward of the beach. These 

mounds are formed by an accumulation of windblown sand that is trapped via obstacles such as 

vegetation. Dunes are dynamic features that erode during periods of high waves (a process termed 

scarping) and rebuild when heavy wave action subsides. The coastal dune ecosystem in Hawai‘i 

functions as a natural, elevated buffer against erosion, flooding, high waves, storms, tsunamis, and 

other coastal hazards (Wagner et al. 1999, UH 2006). 

Native vegetation on sandy or dune areas typically includes ‘aki‘aki, pōhuehue, hinahina, naupaka, 

pōhinahina, nanea, alena, Reichardia picroides, ‘ohai, and nama. In addition to providing habitat for 

native flora, the coastal dune areas at Keālia Pond NWR provide resting habitat for the endangered 

‘īlio-holo-i-ka-uaua, and nesting habitat for endangered honu ‘ea and threatened honu. Dunes provide 

resting and foraging habitat for seabirds and shorebirds including the kōlea and kioea, two shorebird 

species designated as a high conservation concern. These coastal dune areas formerly provided 

nesting areas for the endemic pueo (Mueller-Dombois and Fosberg 1998, Hawai‘i Audubon Society 

2005). 

Recreational and coastal development pressures have severely impacted coastal dunes throughout the 

State of Hawai‘i and the Island of Maui. Commercial and residential developments along the 

coastline level the dune environment. Grading and landscaping alter the naturally occurring 

topography and ecology of dunes. Soil filling, in order to support non-strand vegetation, compacts 

and traps dune sands and sand that is removed by waves cannot be replaced. This trapping causes a 
Keālia Pond National Wildlife Refuge 

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Chapter 4. Refuge Biology and Habitat 4-35 

continual decrease in sand and loss of the beach environment. In addition, the continuous trampling 

by vehicles and pedestrians on the dunes causes erosion and sand movement. Vogt (1979) found that 

fewer than 10,000 pedestrians walking over sand dunes during a single season can eliminate dune 

vegetation and result in erosion. Because the beach area in Hawai‘i is attractive to both visitors and 

residents, pedestrian traffic has a significant impact on these areas (Tabata 1980, UH and Maui 

Planning Department 1997, DLNR 1999). 

Dune management tools at the Refuge include planting native coastal vegetation; controlling pest 

plants; and prohibiting vehicles (including all-terrain vehicles); and using fencing to block turtles 

from entering the roadway. 

4.15.2 Wetlands and Deepwater Habitats 

Lacustrine and palustrine wetlands occur at Keālia 

Pond NWR as delineated by the National Wetlands 

Inventory. Lacustrine wetlands occur in a treeless 

depression and exceed 20 acres. Palustrine wetlands 

are non-tidal and dominated by trees, shrubs and 

emergent vegetation (Cowardin et al. 1979). 

Lacustrine wetlands 

Keālia Pond NWR is named after the main body of 

water that provides all 200 acres of lacustrine 

wetlands on the Refuge. In most years, major 

winter storms fill the pond and water level gradually 

drops throughout the rest of the year. By mid-spring, water coverage drops below the adjacent 

palustrine wetlands and the lacustrine bottom becomes exposed. By summer, water is supplemented 

through a water distribution system and a pump from a brackish-water well. The pond may remain 

nearly full in some years when stream diversions are reduced during the summer. 

Palustrine wetlands 

The vegetated and small unvegetated wetlands surrounding the main pond and Mā‘alaea Flats to the 

west make up 150 acres of palustrine habitat. The wetlands adjacent to the main pond are directly 

influenced by its hydrology. Except for sedge stands fringing the lacustrine wetlands, nearly all 

vegetation is comprised of non-native invasive species, dominated by Indian marsh fleabane and 

pickleweed. The Kanuimanu and Baitfish ponds have vegetated cover of sedges that ranges from a 

fringe along the side slopes to 40 percent coverage. Vegetation at Mā‘alaea Flats is dominated by 

similar invasive species, and sparse stands of sedges. This area is influenced by the hydrology of the 

main pond only at extremely high water level when water backs up onto the flats. Supplemental 

pumping into the main pond does not feed the flats due to mud bars at the outlet stream and, 

consequently, the flats remain dry during the summer. 

Installation of staff gauges in 1995 showed little change in sedimentation in the deeper areas of the 

main pond. Accumulation of wind swept sediments is frequently observed during most summers at 

the southeastern part of the main pond. Transect markers placed along the vegetation line measured 

vegetation encroachment of up to 45 feet. This was likely the result of pumped water being 

discharged in the area during the summer. 

Ponds and West Maui Mountains © Sonny Gamponia
Keālia Pond National Wildlife Refuge 

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Kiawe-dominated dry forest Laura Beauregard/USFWS

In the palustrine wetlands, Indian marsh fleabane appeared in the upper elevations of this habitat 

during a series of dry years. West of the main pond, Pluchea was mechanically removed in 2007, but 

has since become re-established. Pickleweed was mowed in 10 yard bands parallel to the main pond 

shoreline in 2008 and again in 2009. California grass, present since the Refuge was acquired, was 

mechanically removed in 2005. It has since grown back. Red mangrove was removed in 2003 east 

of Kanuimanu ponds. Additional stands were removed in 2005 and 2011. Kanuimanu ponds were 

formerly fish farm ponds that were re-contoured for waterbird habitat in 2006. The former baitfish 

ponds were redesigned in 2007. 

Although Keālia Pond may provide over 100 acres of shorebird habitat, the absence of water control 

structures limits shorebird use of vegetated habitat most of the winter and birds are concentrated in 

exposed shallow water edges. Mā„alaea Flats is partially flooded only after the infrequent rains that 

fall on the Refuge. Conversely, water covers most of the mudflats at the main pond except in those 

years when the pond dries out in the fall. 

4.15.3 Coastal Dry Forests 

Hawaiian dry forests once supported a remarkable 

diversity of tree species, however, researchers 

estimate 99 percent of the original coastal dry forest 

has been removed. The arrival of humans caused 

the most severe environmental impacts to the 

lowlands because these areas were favorable for 

human habitation. Coastal dry forests were cleared 

with fire followed by slash-and-burn agriculture. 

Charcoal evidence from Maui has shown that 

lowland areas were subject to frequent fires after 

human settlement (Kirch 1982, Cabin et al. 2000, 

Burney and Burney 2003). 

Coastal dry forest at Keālia Pond is species poor with the majority of plants introduced since the 19th

century. Kiawe has replaced native plant species within the higher elevations of the Refuge, 

primarily along the northern border above the seasonally inundated zone. Trees are typically 30-40 

feet tall. In open areas, understory of thick buffel grass is dominant with fingergrass. In wetter 

areas, pickleweed is the dominant understory species along with „akulikuli and Indian marsh 

fleabane. It can dominate semi-arid areas by using the brackish groundwater. 

A variety of non-native birds inhabit this forest including gray francolin, black francolin, Northern 

cardinal, red-crested cardinal, and house finch. The necessary biological requirements of „ōka„i „aiea 

adults for foraging, sheltering, dispersal, breeding, and egg production are native, nectar-supplying 

plants and the dry to mesic habitats between the elevations of 0-5,000 ft. Although only a few „ōka„i 

„aiea have been reported at Keālia Pond, with restoration management the coastal dry forest area of 

the Refuge has the potential to meet these requirements. 

While non-native plants are a threat to remaining fragments of dry forest, the complete or rapid 

removal of non-native plants may have a negative impact on native species by changing forest 

structure, microclimate, and disturbance involved with plant removal activities. Thus, small scale and 
Keālia Pond National Wildlife Refuge 

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Molokini © F & K Starr

large scale experimental plots that remove some or all of the non-native species may provide insight 

on how to best manage the coastal dry forest at the Refuge (Pau et al. 2009).

4.15.4 Offshore Islet (Molokini) 

There are no known federally-listed threatened or 

endangered species of migratory seabirds on the 

islet. The islet is important nesting and roosting 

habitat for at least six species of seabirds. A large 

colony of ‘ua‘u kani of approximately 3,200 adults 

was recorded in 1978. Molokini also has confirmed 

nesting of ‘ou, a species with a population of 

moderate concern. Other seabirds, including ‘iwa, 

‘ā, and noio, frequently use the islet for roosting. 

A banding program was initiated on Molokini in 1999 by DLNR. It is an annual effort for known 

Maui Nui colonies on Maui, Moloka‘i, Lana‘i and offshore islets ‘Ālau and Molokini (total of 9 

sites), providing a County-wide assessment. In comparison with other sites, Molokini consistently 

shows a much higher number of birds banded than other main island sites, primarily because of the 

absence of predators and human disturbance. From 1999-2010, the number of chicks banded ranged 

from 400-650 nestlings, which is approximately 1/3 of the total active nests. State biologists started 

banding adult birds at Maui colonies a few years ago and have recovered birds originally banded on 

Molokini, confirming the dispersal of birds from Molokini to other colonies. Unfortunately, colonies 

on the main Hawaiian Islands are subject to high predation by non-native mammals and incidences of 

human disturbance (shooting, eating, caving-in burrows), resulting in very low fledging success 

(Fern Duvall, pers. comm.). 

‘Ou are known to nest in rock crevices on Molokini; however, number of nesting pairs, active nests, 

and fledging success is unknown. This species cannot exist in the presence of mammalian predators 

that are prevalent on the main Hawaiian Islands, including mongooses, rats, and cats. This 

emphasizes the value of offshore islets such as Molokini for ground nesting seabirds. 

The earliest botanical surveys were conducted in 1913 (Forbes) and 1925 (Palmer). Only 10 species 

were common to both visits and, of the total 21 different plants, 11 were native speices. In 2006, the 

Offshore Islet Restoration Committee (OIRC) recorded 35 plant species, only 9 of which were 

native. Molokini is vegetated with non-native buffel grass and 6 of the native plant species, 

including ‘ihi, pa‘u o hi‘iaka, koali, ‘iwa‘iwa, ‘ōhelo kai, and ‘ilima. Tree tobacco, which is a host to 

the endangered ‘ōka‘i ‘aiea on Maui, is also present, in addition to other pest plant species (OIRC 

2006). 

One of the management objectives is to restore native coastal vegetation. It is expected that part of 

the habitat restoration program would allow for transplant and restoration of many of the native 

plants that were historically recorded on Molokini. This effort would increase the wildlife value of 

the islet which is already excellent habitat for migratory seabirds and increase the chances of 

continued survival for ‘ōka‘i ‘aiea. The islet has burrows for underground bird nesters and numerous 

plant species make for excellent above ground seabird nesting. 
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4.16 Ecological and Biological Research 

The wetlands are an ecological unit that has a multitude of interconnections between and amongst the 

physical, biological, botanical, and environmental variables. The presence of nuisance issues 

(spotted-winged midges, tilapia, and windblown sediment) emphasizes the need to gain a better 

understanding of these interactions in order to address the individual issues. Changing one link in the 

chain may impact another function or process within the wetland. 

In 2000, the Refuge held a workshop to discuss the existing and future potential of the Refuge to 

increase endangered waterbird abundance, define restoration activities to optimize habitat for 

waterbirds, and identify data gaps that need to be filled to gain a better understanding of the seasonal 

conditions. Results of the workshop provided a basis for subsequent research and inventory projects 

that were completed from 2001-2007. This information gathering phase was instrumental in 

identifying the Refuge‟s goals, objectives, and strategies. 

Projects completed during this time period include: 

Topographic mapping of Keālia Pond (Figure 3.11); 

Preliminary soil characterization (soil composition, profiles) on the vegetated flats; 

Sediment samples from the main pond and stream channels that supply water to Kealia Pond 

analyzed for contaminants (organic compounds, metals, and nutrients); 

Capacity of existing brackish-water wells evaluated (groundwater feasibility study) and all 

three refurbished with two outfitted with more efficient pumps; 

Water distribution lines installed on wells A and C to deliver water to target areas; 

Staff gages installed to monitor surface water levels; 

Piezometers installed to monitor groundwater levels; 

Datalogger installed for continuous water level recording in the main pond; 

Weather gauge replaced for weather data and future evaluation of evapotranspiration rates; 

Comprehensive water monitoring program, including data and analyses of surface water, 

groundwater, abiotic factors (pH, conductivity, dissolved oxygen, salinity, temperature, 

turbidity), and water quality (nitrates, phosphates, and suspended solids) 2001-2004; 

Chemical analyses of excess water from Mā„alaea Power Plant as a potential source of water 

for the wetlands: Although the water did not contain contaminants, this option was rejected 

because the water was nutrient-rich which could result in higher eutrophic conditions in the 

pond; 

Stream flow into Keālia Pond evaluated: USGS installed temporary staff gages on the upper 

reaches of the streams to monitor periodicity and flow. The study also included seepage runs 

to identify how much water was reaching the bounds of the wetlands; 

Larvicide study to test the effectiveness of Bacillus thuringiensis var israelensis (Bti) and smethoprene, on the nuisance spotted-winged midges (2001). Bti comes in a pellet form that 

sinks to the bottom and upon consumption, kills midges and other invertebrate larvae (not 

species-specific) whereas s-methoprene is an insect growth regulator that inhibits the midge 

larvae (species‟ specific) from changing from larvae stage to adult flying stage. Methoprene 

was more efficient at controlling midge abundance because it is specific to midge species, 

only needs to be in contact with midge larvae to become effective, effective period lasts for 

up to 28 days (compared to Bti‟s effectiveness of 2-4 days); and the methoprene only acts as 

a hormone suppressant that allows the larvae to live but not change to an adult (which is the 
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Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 4. Refuge Biology and Habitat 4-39

nuisance). A literature search of methoprene did not result in any documentation that the 

pellets directly, or indirectly, impacted wetland bird species; 

Midge study (3-year) to investigate the life history, density, larvae-adult emergence, and 

control using methoprene. The life history information gained from this study was essential 

in defining the protocol for future monitoring and methoprene treatments. The study results 

provided us with information to develop a standard protocol for controlling midges based on 

available data. There are specific criteria that need to be met to reduce potential, unknown 

impacts to waterbirds and target the nuisance midge species with minimal impact to the 

native species. Spotted-winged midge abundance differs each year and their 

presence/absence in the wetland is due to a combination of ecological, biological, and 

environmental conditions that are difficult to separate in the field. Midge larvae densities are 

monitored from core samples which are the most effective method to identify the peak season 

when treatment can be performed. Only one treatment is conducted in a season to prevent 

resistance to the methoprene. The use of methoprene to control midges is considered a shorttem method while the Refuge investigates more “natural” forms of control. We have 

observed a lower density of midges when water level is low, even during December-January 

which hints at the potential to use water level as a control method; 

Native and introduced invertebrate community. A preliminary inventory of aquatic 

invertebrates (Appendix A) at Keālia Pond was produced from this study; 

A fish study was completed that provided preliminary assessment of fish population in the 

main pond, recruitment into the pond, morphology, and diet. As expected, there is low 

diversity of fish species in the pond, a majority of which were tilapia. The researchers were 

unable to identify any native fish species that could tolerate the seasonal conditions that occur 

in the wetland; and 

Kanuimanu Ponds were recontoured to provide safe access to the public and create habitat for 

endangered and migratory waterbirds. Physical improvements included: grubbing all 

vegetation from levees; removal of interior levees to create larger management units; buildup 

and compaction of pond levees; sloping sides to minimize erosion and create shallow water 

along the edges when water is high; outfitting Well C (brackish water) with a pump and 

electrical service; and installation of a water distribution line to direct water to individual 

ponds. This project and volunteers‟ native outplanting has created better quality habitat for 

foraging and nesting waterbirds. 

Published studies include the following: 

Rader, J.A. 2005. Response of Vegetation and Endangered Waterbirds to Habitat 

Management Techniques at Keālia Pond National Wildlife Refuge. University of 

Missouri, M.S. Thesis. 93pp. 

The objective of this study was to measure and evaluate the response of vegetation and endangered 

waterbirds from mechanical treatment of vegetated flats. Results of the study indicated a difference 

in vegetation (primarily pickleweed) response from mowing and rototilling between areas of the flats 

resulted in an increased interspersion of open water; however, the plots differed in the type of 

vegetation that came in: plots on the east side of the flats came back as monotypic pickleweed and 

the western plots responded with a more diverse assemblage of native plants and annual invasives. 

Opening up the vegetation on the flats resulted in a higher use of the area by endangered and 

migratory waterbirds. Both „alae ke„oke„o and ae„o used the area for nesting and further 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

4-40 Chapter 4. Refuge Biology and Habitat

observations indicated Hawaiian waterbirds depend on early successional habitat for nesting and 

foraging. 

Wirwa, N.L. 2007. Macroinvertebrate Response to Management Strategies and Habitat 

Condition at Keālia Pond NWR, Maui, Hawaii. South Dakota State University, M.S. 

Thesis. 143pp. 

The location of this study is on the vegetated flats that followed on earlier research by Rader (2005) 

but the objective was to determine the macroinvertebrate relationships within specific plant 

communities and habitat conditions, particularly areas associated with mechanical treatment of 

invasive pickleweed. This study emphasized the importance of vegetation to invertebrate diversity 

and density; however, it is also beneficial to maintain a diversity of habitat types (vegetated, mudflat, 

and open water) to maximize species diversity for endangered waterbirds. 

Koshorek, J.L. 2007. The Benthic Community of Keālia Pond (Maui, HI): Native and 

Invasive Chironomids (Diptera: Chironomidae), Benthic Algae and their Interactions. 

Loyola University Chicago. M.S. Thesis. 150pp. 

The objectives of this research were to investigate the diets of both invasive and native chironomids 

in Keālia Pond to identify their primary food resources, examine the factors influencing one possible 

food source (benthic algae) and to determine if midge densities were related to benthic algal biomass 

and/or community structure. A majority of the midge diet (from gut contents) was accounted for by 

detritus and algae. The study found algal biovolume remained stable in the presence of larval midge 

grazing; however, the population did not appear to be limited by algae as a food source, even when 

midge densities reached nuisance levels. These data provided invaluable information on algae 

species and midge diet that may be instrumental when evaluating control methods. 

These research projects and monitoring programs have provided invaluable information for the 

Refuge to evaluate with respect to understanding the wetland ecology and endangered waterbird 

requirements, all of which need to be balanced with the need to ameliorate nuisance issues. 
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Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 5. Refuge Facilities and Public Use Programs 5-1 

New headquarters and visitor center rendering © RIM Architechs

Chapter 5. Refuge Facilities and Public Use Programs 

5.1 Refuge Infrastructure and Administrative Facilities 

The Refuge headquarters is located at Keālia Pond NWR along the entrance road off of Mokulele 

Hwy. and includes a new VC, metal storage containers, constructed impoundments, and brackish 

water wells with pump and appurtenances. The infrastructure and facilities discussed in this section 

include fences and boundary markers, entrances, roads, earthen trails, administrative and 

maintenance structures, and water-related structures (Figure 5.1, page 5-5). Facilities associated with 

specific public use programs (boardwalk, visitor/EE shelter) are discussed in section 5.2. 

5.1.1 Headquarters and Visitor Center 

The first office (1995) was in a leased building at 101 N. Kīhei Rd., across from the Refuge. In 

1997, a double-wide trailer was placed near the Kanuimanu Ponds for the 3 staff. In November 

2006, a fire of unknown cause(s) damaged the office beyond repair and a leased officer trailer is 

serving as the base of operations and visitor contact station until a new building is completed. 

Although operation and maintenance cost of the new building is expected to be more than the 

original trailer office, its energy efficiency will help minimize those costs. 

The new Complex headquarters and Keālia Pond Visitor Center (HQ/VC) is scheduled for 

completion by fall 2011. Funded by the American Recovery and Reinvestment Act of 2009, it will 

become the primary visitor contact station for the entire Complex. The building is located off the 

main entrance road and includes administrative offices, an exhibit hall, and multipurpose rooms. The 

design was based on Leadership in Energy Efficiency and Design (LEED) criteria with the goal of 

attaining Silver status. Our LEED elements include the use of photovoltaic panels for power and hot 

water; water efficient fixtures; design and building placement to take maximum advantage of 

ambient lighting; and landscaping with native plants. 
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5-2 Chapter 5. Refuge Facilities and Public Use Programs

The new VC exhibits will portray the cultural history, ecology, and biology of the Refuge. A multipurpose room will be available for special events (e.g., guest lecturers and special presentations). 

5.1.2 Maintenance Facilities 

Our maintenance facilities are comprised of 3 metal shipping containers that serve as storage for 

hand and power tools, biological supplies, and maintenance supplies. These containers are set in a 

fenced maintenance compound where work materials and supplies (pumps, fencing, and carpentry 

tools), Refuge vehicles, and heavy equipment are also stored. The lack of a covered maintenance 

garage exposes our fleet and equipment to environmental elements and increased deterioration. 

Heavy equipment attachments are covered with tarps to provide some protection from the 

environment. 

5.1.3 Trails

The Refuge has two areas accessible for pedestrian use. Although Kanuimanu Ponds and the Keālia 

Coastal Boardwalk encompass only a small percentage of the total acreage of the Refuge, they do 

provide quality experiences for the public while minimizing disturbance to endangered and migratory 

waterbirds. 

The Kanuimanu Ponds (20 acres), located at the end of the entrance road, are earthen ponds 

constructed in 1970 by Global Marine, Co., that later transferred to Pacific Aquaculture Corp. 

operating as Hawai‘i Fish Farm, Inc. The facilities raised freshwater prawns, Chinese catfish, tilapia, 

and apple snails in the ponds and raceways until 1995, three years after Keālia Pond was established 

as a national wildlife refuge. 

The aquaculture operation was terminated by the Service primarily because of the conflict in 

management practices, including target species requirements for water coverage and depth, and 

native versus nonnative aquaculture species. Raising fish requires constant high water which limits 

waterbird use of the ponds, especially for wading birds like the ae‘o. The endangered status of ae‘o 

and ‘alae ke‘oke‘o requires us to ensure that management practices are optimal for their foraging, 

resting, and nesting requirements. 

The Kanuimanu Ponds’ levees were severely undercut and covered with dense pickleweed and 

Indian marsh fleabane to an extent that areas had be closed to the public for safety reasons. In a 

collaborative effort with Ducks Unlimited, Inc., we implemented a restoration plan to enhance 

habitat for endangered waterbirds and also maximize visitor experiences in wildlife-dependent 

activities (e.g., wildlife observation). The removal of invasive plants, increased elevation and 

width, and subsequent planting of native species has resulted in a safer path and creation of more 

diverse habitat for endangered waterbirds, throughout the year (e.g., shallow water habitat, better 

protection from mammalian predators, and chicks’ access to adjacent ponds). The earth work was 

completed in 2004. Outplanting of native species and control of invasive plants are continuous 

projects to maintain the integrity of the levees and habitat quality. 
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Chapter 5. Refuge Facilities and Public Use Programs 5-3 

The 2,200 foot-long elevated Keālia Coastal 

Boardwalk is located off N. Kihei Rd. at Mā‘alaea 

Flats. The $2.2 million cost for this boardwalk and 

parking area was primarily funded by Central 

Federal Lands Highway Division (CFLHD). We also 

received funding from other Federal, State, and 

County agencies, non-government organizations, and 

local businesses. The purpose of the boardwalk is to 

provide public access into an area that is sensitive to 

pedestrian and vehicular traffic, and prevent illegal 

entry onto the flats when waterbirds are nesting. 

The decking, handrails, and cap rails of the 

boardwalk are constructed of recycled wood/plastic composite lumber, one of the prime uses for 

recycled plastic trash bags and waste wood fibers. The composite material contains no toxic 

chemicals such as those used in conventional treated lumber. Recycled wood/plastic composite 

lumber typically consists of a 50/50 mix of wood fibers from recovered saw dust and waste plastics 

that include high-density polyethylene, polyvinyl chloride (PVC), and others. This material has a 

longer lifespan than solid wood products, which results in lower maintenance and replacement costs, 

no matter how harsh the environment. Since the official opening of the boardwalk in September 

2009, repair needs have been limited to defective boards which were replaced by the manufacturer. 

5.1.4 Roads and Parking Areas

The Refuge’s main road is the entrance road off Mokulele Hwy. on an access/utilities easement from 

A&B Properties. The 0.5 mile asphalt road leads to the HQ/VC, greenhouse, and Kanuimanu Ponds. 

Another right-of-entry from A&B Properties is for access to the old Baitfish Ponds through the sugar 

cane fields; however, this dirt road is not open to the public. Parking areas on the Refuge include the 

visitor center (30+ spaces), maintenance area, Kanuimanu Ponds (7 spaces), and the Keālia Coastal 

Boardwalk (15 spaces and 2 bus parking stalls). 

5.1.5 Fences and Gates 

The Refuge has both wood and chain-link fences and metal gates to maintain, some of which came 

with the perpetual conservation easement and, therefore, aged and in need of replacement. Most of 

these older fences and gates are located at the old Baitfish Ponds site. There are sections of barbedwire/kiawe-post fences on the Refuge that are remnants of former grazing operations. Other old 

fences are in the forested areas and have lower priority for removal. Newer fences and gates are 

located at the Refuge entrance, maintenance area, and the boardwalk. The Refuge boundaries are 

delineated by signs but not an encompassing fence. 

 5.1.6 Wells, Pumps, Water Distribution Lines, and Water Control Structure 

The priority facilities at the Refuge are the three brackish water wells and sump with associated 

water distribution lines. These must be kept in proper condition to manipulate water in the main 

pond and constructed ponds, particularly during the driest months August-November. Originally, we 

used three wells that were constructed in 1970 for the aquaculture facility; however, the 25-foot 

Keālia Coastal Boardwalk © Sonny Gamponia
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

5-4 Chapter 5. Refuge Facilities and Public Use Programs

casings (8 in. pipe) on two of the wells were extremely corroded and required continuous repairs. In 

2010, these wells were abandoned and capped, and new wells were drilled. These new wells are 

outfitted with high capacity (800 gpm) pumps that are more efficient in energy use and pumping 

capacity than past pumps. Each pump is tied in to a water distribution line that directs water to 

different areas of the wetlands: the Kanuimanu Ponds (Well C); the main body of water on the east 

side (Well A); and the north-central area of the main pond (Well D). All wells are 90-100 feet deep 

and contain brackish water (2-4 ppt salinity) used for wildlife and habitat management purposes. 

Installation of pumps and electrical service on Wells C and D was completed in April 2011 and will 

be operational this fall when conditions are typically the driest (August-December). This will be the 

first season the new wells and pumps will be in full operation. The wells and pumps are expected to 

last well beyond the scope of this CCP. 

The old Baitfish Ponds, located on the northwest side of the Refuge were recently (2007) 

reconfigured to combine the six individual ponds into one management unit. A sump, remnant of the 

aquaculture facilities, is used to pump water into the pond through a water distribution line. The 

current setup with a 425 gpm pump is the maximum capacity for drawing water from the relatively 

shallow (25 ft) sump and meets the Refuge’s needs for that area. 

 

A concrete culvert under the N. Kīhei Rd. bridge connects the main body of water north of the 

highway to the ocean; however, a sand plug forms naturally and prevents continuous flow. This 

culvert was likely intended to only pass water 

through; however, it has become an important 

component of the Refuge’s water management 

program and capabilities to hold water or release 

water for the benefit of endangered waterbirds. 

Ideally, the Refuge would like this culvert to serve as 

a water control structure with gates and flashboards 

in order to maintain high water during ‘alae ke‘oke‘o 

nesting season and provide the capability of 

releasing water, as needed. The design for this water 

control structure has been prepared; however, 

funding for construction has not been provided. 

5.1.7 Visitor and Environmental Education Shelter 

A 2.5-sided EE shelter is designed and planned for construction after August 2011 and will be made 

of steel and wood on a concrete pad at the Kanuimanu Ponds on the old office trailer’s footprint. The 

intent is to provide visitors and school groups relief from the sun and wind. This project is high 

priority for funding by the CFLHD discretionary program. Interpretive panels will be included at the 

site.

Sand plug between ponds and ocean USFWS
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 5. Refuge Facilities and Public Use Programs 5-5 

Figure 5.1 – Administration & Public Use Facilities 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

5-6 Chapter 5. Refuge Facilities and Public Use Programs

To preserve the quality of the map, this side was left blank intentionally. 

 
Keālia Pond National Wildlife Refuge 

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Chapter 5. Refuge Facilities and Public Use Programs 5-7 

5.2 Visitor Services 

When the Refuge was established in 1992, management oversight was from the Hawaiian and Pacific 

Islands NWR Complex office in Honolulu. The first Refuge manager, wildlife biologist, and Refuge 

ranger were hired in 1994 to provide on-site management. At that time, the aquaculture facilities, 

with buildings, fish tanks, and pumps, were still in operation. Our initial priorities were to monitor 

the resources (primarily waterbird use) and interact with the community. During the first year open to 

the public (1994-95), 95 visitors came to the Refuge. Visitation has increased to nearly 10,000 in 

2009-10, primarily as a result of increased visibility (entrance signs, cleared entrance, and expansion 

of Molulele Hwy.), outreach (off-site interpretation, special events, and public meetings), and 

additional structures that are accessible by the public (Keālia Coastal Boardwalk). 

The Refuge has the option of closing areas to public access during critical periods of endangered 

waterbird breeding seasons. In past years, some or all of the Kanuimanu Pond levees have been 

closed during aeo nesting and chick rearing periods, and to a lesser degree ‘alae ke‘oke‘o nesting 

season. These closures are temporary and intended to prevent human disturbance to waterbirds and 

protect the public from aggressive birds protecting their eggs or chicks, primarily ae‘o that are most 

susceptible to disturbance (April- July). These closures have not totally impaired visitors’ 

opportunities to view birds as many of the birds are visible from the parking area. Increased numbers 

of waterbirds nesting in these ponds has resulted in more opportunities to observe birds and their 

chicks. 

The Refuge also has the option of closing all, or portions of, the Keālia Coastal Boardwalk if the 

public activity is shown to disturb endangered waterbirds. This has not yet been necessary given the 

current water conditions (e.g., Mā‘alaea Flats becomes dry in June/July) and the minimal, or absent, 

nesting activity. 

Our new visitor services manager has oversight of the public programs including the visitor center, 

volunteers, EE, and interpretation. Although a majority of the visitors arrive from the continental 

United States, the Refuge also receives a large number of international visitors (Canada, Asia, and 

Europe) and the highest visitation is usually during January-February. 

5.2.1 Accessibility of Recreation Sites and Programs 

The Keālia Coastal Boardwalk is 8 feet wide and can accommodate two passing wheelchairs and 

slopes are within Americans with Disabilities Act (ADA) requirements. The new HQ/VC is also 

designed to meet ADA standards. The earthen levees of the Kanuimanu Ponds have some limitations 

on accessibility. The levees are wide, flat, and compacted to allow minimal effort for wheelchairs; 

however, due to the nature of the ponds there aren’t handrails or hold bars available. An advantage 

at this site is the close proximity of waterbirds to the parking area and start of the levees. All of the 

Refuge visitor facilities have accessible parking stalls marked for “Placard or Special License Plate 

Required.” 

 
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5-8 Chapter 5. Refuge Facilities and Public Use Programs

5.2.2 Special Use Permits 

All activities on the Refuge are evaluated to ensure they are compatible with Refuge purposes. 

Public use activities include, but are not limited to: wildlife observation, photography, EE, and 

interpretation. Compatibility Determinations (CDs) for these activites were approved in 2004. These 

CDs and are included in this CCP/EA for an updated evaluation (Appendix B). The areas open to the 

public are concentrated in a relatively small percentage of the Refuge’s total acreage mainly to take 

advantage of what already existed when the Refuge was established. Wildlife observation and 

photography are general uses; however, EE programs require a SUP to identify specific activities and 

general conditions that are allowed while performing the activity, particularly since the programs 

include sampling for educational purposes. 

Periodically, the Refuge receives requests to access the wetlands beyond these public areas for 

research, photography, or other purposes. If approved by the Refuge Manager, a SUP is issued. 

Examples of past approved uses include: Refuge research projects; outside research projects 

(universities); and Federal, State, and County investigations (e.g., updating flood zone maps and 

streamflow surveys). 

5.3 Wildlife Observation and Photography

The Kanuimanu Ponds provide the primary wildlife viewing and photography access at the Refuge 

for visitors. A walking trail around the ponds is an easy stroll and, although it is an earthen path on 

pond levees, it is accessible to visitors in wheelchairs. Access is permitted when the gate is open and 

staff is present. These ponds are the most heavily used by visitors, many of which are birdwatchers 

and amateur photographers. The highist quality wildlife viewing opportunity occurs August-April 

when there is a high diversity and abundance of endangered waterbirds and migratory bird species. 

The Keālia Coastal Boardwalk at Mā‘alaea Flats has interpretive panels and 3 kiosks that tell the 

story of the wetland and its ecological and biological functions. The boardwalk includes three ramps 

that provide access to the beach. Access to the boardwalk is provided year-round (365 days, 

including Federal holidays) from 6:00 a.m. to 7:00 p.m. Gates were installed to prevent nighttime 

parking and camping at the facility. The boardwalk’s location off the highway makes it very visible 

and popular with visitors and residents. 

 

Photography for professional or commercial use on the Refuge requires a SUP. 

5.3.1 Desired Future Conditions for Wildlife Observation and Photography 

The Refuge has identified additional opportunities for the public to engage in wildlife observation 

and photography. Viewing into the main pond from the Kanuimanu Ponds can be enhanced by 

creating higher elevation platforms off the levees. This would require widening areas of the levees 

bordering the main pond. This would allow visitors a better vantage point on a relatively flat surface. 

In addition, photo blinds would benefit photographers and birdwatchers. A vegetated blind was 

considered; however, woody vegetation impairs the integrity of the levee so our preferred option is to 

construct a blind that would blend with the environment and withstand the regular tradewinds. 
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Chapter 5. Refuge Facilities and Public Use Programs 5-9 

Although the location of the boardwalk is beneficial for informing and educating the public, the 

quality of wildlife observation is low due to the current lack of water management capabilities at 

Mā„alaea Flats. In most years, the Flats are dry from mid-June to December so wildlife observations 

are limited to the pond outlet. The value of the visitors‟ experience can be increased if the Refuge 

had the capability to maintain shallow water habitat on the Flats during the dry season. This could be 

accomplished by constructing a well, pump, and waterline on the upper flats. 

Parking at the Kanuimanu Ponds is limited and is not likely to accommodate the increased visitation 

expected with the new HQ/VC. An alternative to driving further down the Refuge road to access the 

ponds is to walk along the road (0.3 mile) and, in the future, construct a boardwalk from the HQ/VC 

to the ponds. The path of this boardwalk would traverse through kiawe forest, pass by a small 

permanent pond on the west side of the road and terminate at the Kanuimanu Pond parking area. 

This would facilitate interpretation of non-native passerine birds, invasive species, and other related 

topics. 

The Refuge has limitations on opening new areas to public access because our priority is to protect 

endangered waterbirds. Currently, only the boardwalk is open 365 days a year. Kanuimano Ponds 

and the current office are open Monday-Friday, except for Federal holidays. With additional staff, we 

plan to have the VC and Kanuimano Ponds open on weekends in the future. 

5.4 Interpretation

Interpretation at Keālia Pond NWR is in the form of displays, exhibits, and verbal communication 

that highlight the ecology, biology, and cultural history of the area to accommodate a diversity of 

visitor interests. The VC exhibit hall will provide 2- and 3-dimensional displays and hands-on 

activities for the public. The diversity of topics that can be interpreted on the Refuge includes 

everything from watersheds to aquatic invertebrates and careers in natural resource fields. 

The Keālia Coastal Boardwalk is not staffed so the interpretive panels are essential for informing the 

public about the resources and the ecological and biological functions that are either visible or hidden 

from view. A map indicates the location of the headquarters where visitors can have one-on-one 

interaction with Refuge staff and volunteers. 

Currently, visitors check-in at the temporary office and are on their own to explore public access 

areas of the Refuge. Interpretive tours are available upon request and are typically given to school or 

other groups rather than individuals. The tours are designed to meet the needs or interests of the 

group with the intention of supplementing their in-class curriculum. Most school group tours include 

hands-on exploration, including: water quality sampling, invertebrate sampling, invasive plant 

removal, and native planting. The interpretive program is popular with groups that are limited on 

time (2-3 hours) but want participants to experience the natural environment. 

Off-Refuge interpretive programs are provided by staff and volunteers, as requested and if time 

permits. These programs have been held for school groups, County of Maui programs (Kaunoa 

Senior Center, Parks and Recreation), and Mainland groups (Elderhostel, birding groups). 
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5.4.1 Desired Future Conditions for the Interpretation Program 

We would like to increase outreach to local groups and visitors to direct more attention to the Refuge 

as an outdoor learning experience. Specialized tours could be developed to meet the needs of the 

public. This will increase the Refuge‟s visibility as part of the community where people can explore 

the natural resources and gain a sense of stewardship in becoming involved with refuge programs. 

5.5 Environmental Education

Our goal is to provide a quality EE program with 

specific learning objectives and diverse hands-on 

opportunities. We seek to have the students engaged 

outside where all senses are utilized. Thus, the new 

HQ/VC does not include an indoor classroom; EE 

shelter is outside where students can become engaged 

in hands-on activities. Environmental education (as 

opposed to interpretation) is a formal program geared 

towards school curriculum for specific grade levels 

and compliant with DOE requirements. Our current 

EE program is minimal due to staff availability to 

plan, design, and implement an appropriate wetland 

education program.

In lieu of Service staffing, EE is a collaborative effort with non-government educational 

organizations that have developed a wetland curriculum based on DOE standards. The organizations 

that regularly use the Refuge for EE are Hawai„i Nature Center (since 1997) and Maui Digital Bus 

(since 2005). Under a SUP, these groups coordinate the schedule and provide the instructors for the 

school group while the Refuge provides the site. This has proven to be a worthwhile cooperative 

effort, which brings more than 1,300 students to the Refuge annually. A majority of the students are 

within the Hawai„i Nature Center program. Their wetland curriculum is popular with teachers and 

includes all aspects of the wetlands, including wetland function, bird observations, invertebrates, and 

biology (food chain, bird behavior, mucking in the mud for invertebrates). 

Maui Digital Bus has an innovative program that teaches students the use of technologically 

advanced equipment, including: water quality dataloggers, digital microscopes, and geographic 

information system (GIS). A small bus was renovated into a mobile laboratory where students can 

examine their samples (water, invertebrates), map locations with GPS, and gain hands-on experience 

using advanced field equipment. This organization is growing in popularity and is continually 

expanding upon their programs. Currently, the Refuge is working with Maui Digital Bus to 

formalize an environmental education program specific to Keālia Pond NWR. 

5.5.1 Desired Future Conditions for the Environmental Education Program 

Refuge-specific EE programs will be developed for school groups of varying age levels. 

Development of all programs will include pre- and post-visit materials for the teachers use once they 

return to the classroom. Teachers‟ workshops will be held annually to introduce the teachers to the 

Students at Keālia Pond © Jay Franey
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 5. Refuge Facilities and Public Use Programs 5-11

opportunities so they can incorporate an onsite visit with their classroom activities. Volunteers 

would be recruited and trained to assist with the program. All EE programs will have a stewardship 

component where students would participate in a wetland restoration project. Currently, this includes 

hand removal of invasive plants and outplanting native plants.

A program for upper-level students (9-12th grades) will be developed based on scientific 

methodology. Students would be given a management issue and within the school year or semester, 

they would develop the methods to sample, evaluate, and form conclusions to what they observed. 

This concept was piloted with Baldwin High School (built nest platforms), Kīhei Charter School 

(comparison of invasive plant controls), Lahainaluna High School (GIS), and Maui High School 

(GIS) with good results. Development of hands-on opportunities will give students a chance to 

experience a biologist career-field and also provides another tool for investigating alternative 

management methods for the Refuge. Other opportunities will likely become apparent as the Refuge 

implements programs and receives feedback from teachers and educators. 

5.6 Volunteers 

Refuge volunteers are a vital component to the operations and management of Keālia Pond NWR. 

Currently, 45-60 volunteers provide over 4,000 hours of labor on the Refuge annually. Our volunteer 

projects include: Dawn Patrol, habitat management, invasive species management, progation and 

outplanting of native plant species, maintenance, and interpretation. 

5.6.1 Desired Future Conditions for the Volunteer Program 

With additional staffing, we will put more effort into recruiting volunteers for all programs 

(biological, habitat, visitor services, education and interpretation). Development of a friends group 

“Friends of Keālia Pond NWR” is a high priority. Through the friends group we plan to recruit and 

train new volunteers for staffing the visitor center and boardwalk. 

5.7 Partnerships

Since 1997, the Refuge has collaborated with National Marine Fisheries Service (NMFS), DAR, and 

Hawai„i Wildlife Fund to monitor sea turtles (honu and honu „ea) nesting on Maui. As a partner, the 

Refuge recruits, trains, and manages a group of 40-50 volunteers, called the Dawn Patrol, who are 

assigned to walk sections of beach from Mā„alaea to Mākena and Lahaina to Kā„anapali, JuneSeptember. Information on individual nesting females and hatching/emergence success for Maui 

contributes towards protecting and providing for threatened and endangered marine life, and 

contributes to the state-wide monitoring effort. 

The growing concern and stewardship of Maui‟s terrestrial, wetland, and ocean resources, has 

resulted in numerous other collaborative efforts between Federal, State, County, non-government 

organizations, and individuals in the form of partnerships. The Refuge participates in partnerships to 

share information and work towards common goals of preserving, restoring, and outreaching 

stewardship opportunities to others. Partnerships are primarily ecosystem based with the common 
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denominators concentrating on shared issues or problems. An increasing effort to combine resources 

has brought together the sharing of information and a more cohesive identification of Maui‟s target 

issues. Additional partnerships include: 

Southeast Maui Watershed Partnership 

Maui Invasive Species Committee 

Maui Conservation Alliance

Maui Wildland Fire Working Group 

West Nile Virus Working Group 

Hawai„i Pacific Joint Venture 

Maui Conservation Alliance 

5.8 Law Enforcement

The Refuge is located between two urban areas (Kīhei and Mā„alaea) and susceptible to a myriad of 

law enforcement issues, including theft, vandalism, and trespassing. The highest number of incidents 

occurs along N. Kīhei Rd. where vehicle accidents occur at least six times per year. All these vehicle 

accidents have resulted in damage of Federal property: sea turtle fence made of recycled plastic; 

guardrails maintained by HDOT, and the pipe gates at the boardwalk. Of the accidents reported to 

the Maui Police Department, contributing causes range from sleeping at the wheel to alcohol 

consumption. There has also been damage to the sea turtle fence from vehicles bumping into them, 

either from backing up or not accurately judging its location. All damages are repaired by Refuge 

staff, excluding the guardrail. 

The Keālia Coastal Boardwalk is located within the Refuge boundary; however, it is disconnected 

from the entrance road making it difficult to monitor. Vandalism to the boardwalk occurs frequently 

in the form of graffiti, trash dumping, and trespassing during closed hours. Frequent cleanups are 

needed after tresspassers have used the area to party and drink alcohol. In 2007, a bronze turtle 

sculpture located at the westernmost kiosk was stolen. It was returned to police a couple months 

later. On another occasion, vandals removed the nuts/bolts of one section of the same kiosk for what 

appeared to be a jumping-off site for mountain bikes or a motor bike. This is one of the more 

challenging areas to manage and protect because it is visible from N. Kihei Rd. The gates to the 

boardwalk are opened at 6:00 a.m. and closed at 7:00 p.m. by a contracted vendor. Although lights 

may be an advantage to the safety and security of the boardwalk, the Refuge has not installed these 

due to light pollution, sea turtle nesting season (May-December), and nocturnal seabird concerns. 

Theft of Federal property is a continuous concern despite the precautionary measures that are in 

place. The isolation of the Refuge from surrounding lighted areas has been a disadvantage and there 

is a high cost of stolen equipment and supplies. 

5.8.1 Desired Future Conditions for Law Enforcement 

The Refuge will continue to have law enforcement issues, particularly with increased visitation and 

exposure. The Pacific Islands‟ Zone Law Enforcement Officer is stationed on O„ahu and is 

available, as needed; however, due to his/her schedule and availability, the timing is only after an 

incident has occurred and no apprehension or citations have been given. We have identified the need 
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to hire a dedicated Refuge Officer for the Complex in our implementation plan (Appendix C) in 

order to help minimize or prevent incidents from occurring. 

5.9 Outdoor Recreational Opportunities and Trends on Maui

 

The coastal and inland areas surrounding the Keālia Pond NWR have high potential for public 

recreation. Located adjacent to one of Maui‟s main population centers, the area provides easy and 

safe public access to both the aquatic and terrestrial natural resources. The 1998 Kīhei-Makena 

Community Plan states that although careful resource management must be employed to protect 

existing parks, shoreline recreational opportunities and access “must be increased to meet the 

growing needs of the region and island residents.” Area recreation activities include: beachgoing, 

picknicking, swimming, diving, fishing, snorkeling, and canoeing (Maciolek 1971). 

5.9.1 Federal, State, and County Recreational Parks 

There are other Federal, State, and County parks on the Island of Maui that provide different or 

similar types of opportunities for the public. The only other Federal agency devoted to natural and 

cultural resources on the island is Haleakalā National Park located approximately 40-45 miles from 

the Refuge (or 1.5 hour driving). Many of the Refuge visitors engaging in birdwatching also visit 

Haleakalā where they can observe native forest birds and pristine Hawaiian forests. As a sister 

agency, the Refuge welcomes opportunities to collaborate on programs for the public. 

Other wetland managed areas on Maui include Kanahā Bird Sanctuary managed by DLNR and 

Waihe„e Refuge managed by Maui Coastal Land Trust. Both located on the north shore of Maui. 

These wetlands compliment Keālia Pond NWR biologically (waterbird use) and provide visitors 

different vantages and experiences. 
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Chapter 6. Cultural Resources, Social, and Economic 

Environment 

6.1 Refuge Cultural Resources 

The Service’s Cultural Resources Policy defines cultural resources as archaeological sites, historic 

places, objects of antiquity, cultural items, or traditional religious values. This section provides a 

summary of the historical and cultural resources at Keālia Pond NWR, within the surrounding 

Waikapū ahupua‘a, and the moku (district) of Molokini. It discusses the Native Hawaiian and EuroAmerican cultural history of the area, within the context of the broader history of the Island of Maui 

and the State of Hawai‘i. 

The early settlement history of the island is a subject of some debate. Some believe that the first 

Polynesians arrived in Hawai‘i around 100 to 300 BCE from the Marquesas and were followed by 

Tahitian settlers around 1100-1300 CE who conquered the original inhabitants. Others believe that 

there was only a single, extended period of settlement. Polynesians developed a new Hawaiian 

culture while maintaining much of the social and political structure of their homeland. 

According to Kamakau (1961), traditional Hawaiian land tenure was a system formed in order to care 

for the land (malama ‘aina). Around the 14th century, various individual island mo‘i (kings) believed 

the land should be surveyed and permanently marked in order to institute a boundary system that 

would settle disputes between neighboring ali‘i (chiefs). A kahuna (priest) named Kalaika‘ohia is 

said to have carved the land into 12 moku (districts), which were controlled by an ali‘i ‘ai moku. 

These lands were further divided into ahupua‘a, a wedge-shaped land unit that traditionally 

subdivided resources from the uplands to the shore thereby allowing access to marine and mountain 

resources. Ahupua‘a varied in size and were generally delineated by topographical or natural 

boundaries such as mountain ridges and streams. Keālia Pond lies in the Waikapū ahupua‘a, one of 

the four ahupua‘a that make up the entire southern portion of the larger moku of Wailukū. Molokini 

Islet is in its own moku of Molokini (Chinen (1961, Handy and Handy 1972, Orr 2006). 

The idea of holding land was not synonymous with owning it, but more like a trusteeship between 

the caretakers and the nature gods Lono and Kane (Handy & Handy 1972:41). The ahupua`a is the 

most well known of all traditional land divisions and is still relevant today. Traditionally, the areas 

were governed by a designated caretaker (konohiki) and those residing within the region had 

designated access to all mountain and marine resources. Chinen (1961:5) explains that all chiefs and 

commoners were entitled to a portion of the mountain and marine resources. 

 

Wailuku District, is frequently mentioned in historical texts and oral tradition as being politically, 

ceremonially, and geographically important during traditional times (Cordy 1981, 1996; Kirch 1985).

Wailuku was considered a "chiefly center" (Sterling 1998:90) with many of the chiefs and much of 

the area's population residing near or within portions of ‘Īao Valley and lower Wailuku. The 

importance of the district is reflected by the relatively large number of heiau (temple sites) that were 

reportedly present in pre-Contact times. Oral tradition accounts surrounding these heiau provide 

examples of how religion tied into political power in the traditional Wailuku setting. Indeed, the 

period immediately preceding contact with the Europeans was one of considerable upheaval and 

conflict. 
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Political power emanating from Moloka`i was an active element during the mid-eighteenth century. 

The resulting battle at Kalae`ili`ili (A.D. 1765) led to the expulsion of Keeaumoku and the Moloka`i 

ali`i and the beginning of Kahekili’s reign (Kamakau 1992). Kahekili successfully defended his capital in 

Wailuku throughout the 1770s, until his defeat at the hands of Kamehameha’s forces. 

 

Closer to the current project area, in the southwest corner of Wailuku District, prehistoric settlement was 

not as dense as concentrations to the north. Climate had much to do with that trend, as the Ma`alaea area 

is a more arid environment than the rain-soaked fields to the north. According to Tomonari-Tuggle and 

Tuggle (1991), the majority of the pre-Contact population was located west of the project area, near what 

is now Ukumehame Beach State Park. 

 

6.1.1 Mythological and Traditional Accounts 

The Wailukū moku covers the entire isthmus between East and West Maui. This area was also 

referred to as Na Wai ‘Eha, meaning “the four waters,” and is named after the four major streams 

(Waikapū, Wailukū, Waiehu, and Waihe‘e) flowing in the windward portion of West Maui. Wailukū

and its coastal environs are thought to have been initially settled around 1100-1200 CE. Keālia Pond 

lies in the traditional district of Waikapū, which has now been absorbed by the district of Wailuku. Place 

names in the area may help determine ancient Hawaiians’ perspectives toward individual areas. The name 

Waikapu translates literally to “water of the conch” (Pukui 1974:222). W.K. Kaualililehua, in Ka Nupepe 

Kuokoa, cited in Sterling (1998:93) describes the origin of the name: 

The Wai-ka-pu now being discussed was named by some of the ancients and it remains 

by this name to this day. This place, Waikapū, has a cave away up the stream, about a 

mile or more from the village. On the left side of the stream is a cave and in the cave was 

the conch. It sounded all the time, unseen by the public, but a prophet of Kaua‘i listened 

for it and came to seek with the idea of finding it. 

 

On the northeast side of that stream on the opposite side of the conch that sounded, on the 

cliff, was a dog named Puapualenalena. Because he heard it, he sought diligently to find 

it but he did not succeed. Those who guarded the conch were very watchful. The dog kept 

studying ways of obtaining it. 

 

The owners of the conch did not believe, perhaps, that any supernatural being would 

succeed in taking it away, so they tried to be a little careless. It was not taken, but on the 

day that Puapualenalena did get it away, they had been utterly careless. After he took it, it 

sounded no more to this day. It used to be heard every where in these islands and was 

annoying to some people. From this conch, the whole of the place was named Waikapū

(Water of the Conch). 

 

A second hypothesis on the origin of the name was described by G.W. Bates in Sandwich Island Notes, 

cited in Sterling (1998:93): 

 

The first village of any note on the way to Wai-lu-ku is Wai-ka-pu. It contains a 

population of about five hundred. Here the forces of Kamehameha the Great once 

assembled for battle at the sounding of the conch-shell. Hence its name, Wai-ka-pū

(water of the conch or trumpet). 
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Molokini 

Many Hawaiian mythologies involve shape-shifting 

spirits, beings who could change at-will from animal 

to human form. According to legend, the beautiful 

mo‘o (shape-shifting water lizard) Pu‘uoinaina 

married Lohiau, a chief who lived at Mā‘alaea. 

Unfortunately for her, the volcano goddess Pele was 

also in love with Lohiau. In a jealous rage, Pele cut 

Pu‘uoinaina in two and turned her into stone. Her 

head became the 360-foot tall cinder cone called 

Pu‘u Ōla‘i, or Red Hill, which rises above Mākena 

Beach at the south end of Wailea. Her tail became 

Molokini Islet (Kalakaua 1989). 

Native Hawaiians visited Molokini to fish and probably also to harvest seabirds, eggs, and feathers. 

A variety of stone sinkers and lures, used in traditional fishing techniques, are still present in waters 

around the islet (Starr et al. 2010). 

Keālia Pond 

The word “keālia” means “encrusted with salt” and it is said that its “most excellent salt” was made 

using the salt pans in the immediate vicinity of the pond (Sterling 1998). There are ditches and sluice gates

that were built at least 400 years ago to let fish stock such as ‘awa, ‘ama‘ama, and other near-shore fish

into the pond. Ashdown noted alternate names for the area (1971:22-24): 

“Keālia was the huge fishpond attributed to King Uni-a-Liloa after the death of 

Pi‘ilani in Lahaina. It was called the pond of Ka-lepo-lepo because, in one story, Uni 

made his people carry him atop the huge akua stone which was to be placed at one 

part of the pond. The load was so heavy that the workmen dropped it and the king fell 

into the lepolepo (dirty water). Others have insisted that the great chief never did 

suffer such an indignity, like a commoner, but that the name should be Kalepa, 

meaning the fluttering of the flags of canoes there when the area was a port of call 

since ancient times.” 

6.1.2 Pre-Contact History 

 

In pre-contact times, all land from the base of the Waikapū ahupua‘a to below the valley was used for 

extensive wet-taro planting. Handy and Handy (1972) note that the Waikapū Stream, which flows 

down the center of the island isthmus from the West Maui Mountains into Mā‘alaea Bay, was 

“diverted into lo‘i and its overflow was dissipated on the dry plains.” However, most evidence of the 

traditional terraced taro culture has since been eliminated by extensive sugarcane cultivation. Near 

the southern portion of the ahupua‘a, on the flat coastal plains of Kīhei and Mā‘alaea, Handy (1940) 

states that traditional fishing settlements and isolated fisherman houses could be found. In addition, 

sweet potatoes were cultivated in the sandy soil near the shore in these areas. 

Wailukū, meaning “water of destruction,” succinctly describes the area in the late 1700s. Political 

power emanating from Moloka‘i was an active element during the mid-18th century. In 1776, the 

chief of the Island of Hawai‘i, Kalaniopu‘u, gathered 800 warriors just east of Keālia Pond at 

Sunset over Molokini L. Beauregard/USFWS
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Kīheipukoa. He then led them across the Waikapū commons to attack Kahekili, the chief of Maui, 

whose warriors were hiding at the sand dunes of Waikapū. It is estimated that 1,600 people were 

killed in the Battle of Kakanilua. Only 2 of the Maui warriors survived. Another battle took place in 

the area shortly after when Kamehameha the Great landed southeast of Keālia Pond at Kalepolepo 

and invaded the island (Fornander 1969, Athens et al. 1996, Sterling 1998, Desha 2000). 

 

6.1.3 Euro-American Cultural History 

In 1778, British explorer Captain James Cook on the H.M.S. Resolution is credited with being the 

first European to visit Hawai‘i. There is some evidence that Spaniards, who first crossed the Pacific 

Ocean in 1522, also made landfall in Hawai‘i but they never correctly mapped or claimed credit for 

their accomplishment. Cook recorded sighting Maui in November 1778, anchoring near Kahului but 

not coming ashore. In 1786, French Admiral Jean-François Lapérouse of the ill-fated Boussole was 

the first European explorer to come ashore on Maui in an area south of Mākena now known as La 

Perouse Bay. The Boussole and its crew vanished in 1788 and the shipwreck was later found in the 

South Pacific in the current Republic of Vanuatu (Bateson 1972, Speakman 1978). 

Keālia Pond lived up to its name as a source for much needed salt for early sailors to the Island of 

Maui. P. Corney, in Voyages in the Northern Pacific, cited in Sterling (1998:95) recounts: 

 

Feb. 1, 1817... We now made sail towards Mowee, our ship, as usual, full of natives. Next 

morning we passed Morokenee (Molokini), and made sail up Mackerey (Mā‘alaea) bay; here 

we lay until the 6th, and took on board a great quantity of hogs, salt, and vegetables... On 

this neck of land are their principal salt-pans, where they make most excellent salt. 

Contact with Europeans began a series of plagues for which the Native Haweaiians had no 

immunities. Their population fell from 300-500,000 in 1778 to only 30,000 by 1900. As trade and 

shipping brought Hawai‘i into contact with a wider world, it also enabled the acquisition of Western 

goods, including arms and ammunition. In 1795, Kamehameha the Great of Hawai‘i assembled the 

largest army the Hawaiian Islands had ever seen, with over 10,000 men and 1,200 war canoes, 

equipping them with European muskets and cannon. He established the Kingdom of Hawai‘i with the 

subjugation of the smaller independent chiefdoms of O‘ahu, Maui, Moloka‘i, Lāna‘i, Kaua‘i, and 

Ni‘ihau over the period from 1795-1810. 

Lahaina, Maui, became the new capital of the Kingdom of Hawai‘i and was the center of government 

for nearly five decades. ‘Iliahi (sandalwood) was the first major item of external trade. By 1805, 

‘iliahi had begun to reach China, and by 1809 it was a regular commodity. In 1810, American 

merchants reached an agreement with Kamehameha for a monopoly on the ‘iliahi trade in exchange 

for a quarter of the profits. These merchants took a convoy of ‘iliahi ships to China in 1812, making a 

good profit on their sales. This agreement stood for only one shipment, though, and shortly thereafter 

the War of 1812 resulted in a British blockade of Hawai‘i for two years (Daws 1989). 

When trade resumed in 1814, King Kamehameha claimed the trees as his own in a near-monopoly 

and organized the cutting and transport of ‘iliahi under his public works program. The ‘iliahi trade 

encouraged the transition to a cash economy, the purchase of luxury goods, and became the main 

source of revenue for the Hawaiian chiefs. Kamehameha had established commercial trade and 

foreign business ventures as the best means of obtaining the luxury items and other goods. 
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Kamehameha's death in 1819 triggered a dramatic change in the social, political, and religious 

systems of the country. Members of the ali„i had acquired many of the outward manners and dress of 

European civilization during the final years of Kamehameha's reign. His successor Liholiho 

(Kamehameha II) ended the kapu system and ordered the destruction of images and heiau throughout 

the Kingdom. Fires were set in the forests to detect „iliahi trees by their sweet scent. While mature 

trees could withstand the fire, the flames wiped out new seedlings. By 1830, the „iliahi trade had 

completely collapsed (Gast and Conrad 1973, Judd 1966). 

The introduction of horses and cattle around the turn of the 19th century aided in transition from the 

„iliahi trade to ranching. Cattle hides, tallow, and meat became important commodities of local and 

international trade. Hawai„i was a major supplier of beef to California during the Gold Rush and 

subsequently to the visiting whaling ships. At the height of the whaling era (1840-1865) as many as 

500 ships anchored in Lahaina‟s port (Cowan-Smith and Stone 1988). 

6.1.4 The Mahele, 1848-1851 

Among other things, foreigners demanded private ownership of land to insure their investments. 

Influenced by these foreign investors, King Kamehameha III instigated the Great Mahele of 1848 and 

drastically altered the Hawaiian land system by redistributing land ownership between the kings, 

ali„i, foreigners, and maka„ainana (common people who were fishermen, craftsmen, and farmers). 

Once lands were made available and private ownership was instituted the maka„ainana were able to 

claim the plots on which they had been cultivating and living, if they had been made aware of the 

foreign procedures for Land Commission Awards (LCA). These claims could not include any 

previously cultivated or presently fallow land, stream fisheries or many other resources necessary for 

traditional survival (Kelly 1983; Kame„eleihiwa 1992; Kirch and Sahlins 1992). 

If occupation could be established through the testimony of two witnesses, the petitioners were 

awarded the claimed LCA and could then take possession of the property. The land that maka„ainana 

received was less than one percent of total lands. A total of 88,000 people submitted 14,195 requests 

for land and of these only 8,421 were awarded. In 1850, it became legal for foreigners to purchase 

land and they received large portions for reduced prices. At this time, many Native Hawaiians lost 

access to their lands due to mortgage default. Land Commission Awards from that time offer written 

records and insight into the historic land use of the area. In the Waikapū ahupua‟a, claims were 

concentrated on the southeastern edge of Keālia Pond. Nine of the claims surrounding the pond refer 

to salt lands (for salt collection), while four claims document house lots (Chinen 1961, Athens et al. 

1996, Orr 2006).

6.1.5 Post-1850s History 

Another influence that brought change to Maui was foreign commercialism. Two Chinese brothers, 

Ahung and Atai, of Honolulu‟s Hungtai Company set up one of its earliest sugar mills. Atai soon 

created a plant that processed sugarcane cultivated by Hawaiians, named the Hungtai Sugar Works 

(Dorrance and Morgan 2000:15-16). In 1862, The Wailukū Sugar Company was established and 

would expand sugar production over the next 126 years. By the turn of the century, a large portion of 

Waikapū was under sugarcane cultivation. Wailukū Sugar Company ended production in 1988, 

having averaged over 30,000 tons of sugar produced annually at its pinnacle in the 1970s (Dorrance 

and Morgan 2000). 
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The Kingdom of Hawai„i lasted throughout most of the 19th century, when expansion of the sugar 

industry meant increasing U.S. business and political involvement. Through the Reciprocity Treaty 

between the United States of America and the Hawaiian Kingdom of 1875, the United States obtained 

exclusive rights to Pearl Harbor in exchange for allowing Hawaiian sugar to enter the United States 

duty-free. In 1893, Queen Lili„uokalani was deposed in a coup d'état led by American citizens 

supported by the landing of U.S. Marines. The sovereignty of the Kingdom of Hawai„i was lost to a 

Provisional Government led by the conspirators, later briefly becoming the Republic of Hawai„i, 

before eventual annexation to the U.S. in 1898.

Kīhei was transformed by the advent of WW II. The U.S. military development began on Maui in 

June 1940 at the Naval Air Station (NAS) Pu„unēnē located north of the present Refuge. The area 

surrounding Keālia Pond and Mā„alaea Bay was used as a training site for the 4th Marine Division in 

preparation for the Pacific war theater. Over 5,000 marines were housed there. Immediately west of 

the Refuge boundary there is evidence of a firing range and airstrip. While preparing for the 

Marianas campaign in 1943 and 1944, military personnel practiced amphibious landings on the 

beachfront and mudflat areas near the Refuge. Artifacts of these landings, such as concrete and steel 

barriers, or rock jacks, are still found within the area. Molokini was used for target practice (Athens 

et al. 1996, Tome and Dega 2004). 

Following WW II, the Kīhei coastline returned to the peaceful activities of ranching and development 

of residential areas. During the 1960s, development of the area as a vacation haven for tourists and 

homebuyers began, a trend which continues to the present day. 

6.1.6 Refuge Archaeological/ Cultural Surveys 

Athens et al (1996) identifies a “place of note” located northwest of Keālia Pond in Pōhākea. Pu‟u 

Hele is a sacred area where a cinder cone once stood near the junction of the Lahaina, Wailukū, and 

Kīhei roads. Ancient prophecy avowed that Pu„u Hele was a former mo„o who would “cover all 

Maui when the foreign tide envelopes our land and people.” The cultural significance of the hill has 

changed since the cinders were used for road building at the NAS Pu„unēnē and the hill was 

eliminated. 

In 1979, the Service conducted a three-day reconnaissance survey of Keālia Pond, which recorded no 

evidence of historical or archaeological resources at the pond or in the immediate vicinity. Athens et 

al (1996) lead five trench surveys near the coastal dunes and a paleoenvironmental core analysis in 

the mudflat area for the proposed boardwalk, kiosk, and parking project. No historical or cultural 

remains (pre-contact Hawaiian or WWII) were found during the survey. Athens (1996) concluded 

that it is not likely that cultural resources are present within the Refuge boundary due to the site‟s 

close proximity to an active beach and the nearness of the upper soil deposits to the water table. 

The most recent archaeological and cultural investigation occurred in 2009 and was specific to 13 

acres in the forested habitat along the entrance road prior to construction of the new HQ/VC. There 

is no pre-contact evidence within this area; however, the investigation confirmed the area was used 

for cattle ranching from the rock area with cattle troughs. The researchers did not find any new 

evidence of Hawaiian occupation within or adjacent to the Refuge. 
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6.1.7 Archaeological Resources 

The Archaeological Resource Protection Act of 1979 defines archaeological resources as the 

following: “Any material remains of past human life or activities which are of archaeological 

interest” and “at least 100 years of age” (16 USC 470bb(1)). According to 36 CFR Part 296.3, 

remains are considered of archaeological interest if the resources are “capable of providing scientific 

or humanistic understandings of past human behavior, cultural adaptation, and related topics through 

the application of scientific or scholarly techniques such as controlled observation, contextual 

measurement, controlled collection, analysis, interpretation and explanation.” 

Several archaeological surveys and literature reviews have been conducted for Keālia Pond NWR 

and additional projects in the vicinity. These studies show that Keālia Pond was an important 

prehistoric site for gathering salt and may have been used as an ancient Hawaiian fishpond. Apart 

from the pond itself, no archaeological items or sites have been encountered in the area. Any areas 

that may have been suitable for habitation and/or cultural activities were most likely eliminated or 

modified by amphibious landings during WW II (Athens et al. 1996). 

6.1.8 Paleontological Resources 

Unless found in an archaeological context, “nonfossilized and fossilized paleontological specimens, 

or any portion or piece thereof,” are not considered archaeological resources (16 U.S.C. 470bb(1)). 

However, paleontological resources are protected under the Paleontological Resources Preservation 

Act of 2009. Paleontology resources include life forms that existed in prehistoric or geologic times, 

as represented by the fossils of plants, animals, and other organisms. Ziegler (2002) defines fossils 

as “biological remains, whether permineralized or not,” that were “deposited in the islands before the 

time of European contact (CE 1778) and are not definitely components of prehistoric archaeological 

midden (human food refuse and other cultural debris).” Fossils have been uncovered in a variety of 

sites throughout Hawai‘i, including sand dunes, sinkholes, lava tubes, and pond deposits. 

Olson and James (1982) state that no substantial avifaunal fossil deposits have been found on Maui. 

Although the isthmus between East and West Maui may have been a potential fossil site due to its 

calcareous sand composition, the area is largely developed or vegetated. A paleoenvironmental core 

sample was conducted by Athens et al. (1996) to a depth of 17.16 feet within the mudflat area of 

Keālia Pond. In addition to providing information on traditional Hawaiian activities in the area, the 

core was intended to gather data on the prehistoric environment and vegetation. No animal fossils or 

fossils of other organisms were encountered on site during this survey. Radiocardon dating of the 

paleoenvironmental core documented a 5600-year old sequence. Consistent with investigations on 

other Hawaiian Islands, the chronology of the core suggested that the sand berm along Keālia Pond 

developed when sea level was regressing around 3,700-4,000 years ago (Athens et al. 1996). 

Well-preserved pollen and spore samples provide insight into the lowland vegetation of Maui prior to 

human settlement. Overall, the area most likely fluctuated between a parkland/shrubland and a dry 

forest. Similar to studies conducted on O‘ahu, the pollen record in the core showed that the prehuman vegetation at Keālia Pond during the Holocene epoch was influenced by a series of climatic 

shifts. The earliest pollen assemblage (5,600 years ago) was characterized by lowland forests, 

indicating that the climate was warmer and wetter. About 2,000-4,500 years ago, the climate became 

drier. This change is associated with significant volcanic activity, as supported by a period of high 
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charcoal particles in the core. Finally, the pollen record during the late prehistoric period, 1,800-

2,000 years ago, indicates that conditions became wetter again. Periods of concentrated charcoal 

particles in the core reveal that natural fires were common in the lowlands of Maui throughout the 

Holocene (Athens et al. 1996). 

6.2 Social and Economic Setting 

The purpose of this section is to address the local economy and social environment surrounding the 

Refuge, including population estimates and economic indicators. Keālia Pond lies between the towns 

of Mā‘alaea and Kīhei within the County of Maui, which encompasses the Hawaiian Islands of 

Kaho‘olawe, Lana‘i, Maui, and Moloka‘i. There is no habitation on Molokini. 

6.2.1 Population 

The 2010 Census data shows Maui County experienced significant population growth in the past 

decade with a 21 percent increase to 154,834 residents. Of these, 144,444 are living on the Island of 

Maui. The State Department of Business, Economic Development, and Tourism’s (DBEDT) released 

data on Maui’s racial make-up from the 2010 Census. The white race group had the largest number 

of people with a count of 74,329 and they comprised 52 percent of the population; meaning that 

about 1 in every 2 persons was at least partially white in Maui County. The Asian group was the next 

largest with 66,925 people or 46 percent of the population. The Native Hawaiian and Other Pacific 

Islander race group consisted of 36,971 people and made up 26 percent of Maui’s population. This 

meant that about 1 in every 4 of Maui’s residents claimed to be at least partially Native Hawaiian and 

Other Pacific Islander with regard to race (Census 2010). 

Data numbers specifically refer to the “race alone or in combination”, and include all people that 

belong to a certain race group, whether the person reported that they were only of that single race or

whether they reported that they were that race in combination with one or more of the other major 

race groups. Therefore, individuals may be counted in more than one race category. 

For the first time, the combined communities of Kīhei and Wailea have taken the lead as Maui's 

largest town with a population of 26,918 in 2010. There has been a tremendous influx of new 

residents compared to 1970 when the Census Bureau did not even acknowledge the existence of a 

community in South Maui. A much smaller community, Mā‘alaea saw a 22.5 percent population 

decrease since the 2000 census for a current count of 352 (DBEDT 2011). 

Table 6.1. Population figures for selected areas. 

Area Population 

(1990) 

Population 

(2000) 

Population 

(2010) 

Density per Sq 

Mi (2010) 

Kīhei 11,107 16,749 20,881 2,055.3 

Mā‘alaea 443 454 352 73.8 

Maui Island 92,566 118,371 144,444 198.7 

Maui County 100,374 128,094 154,834 133.6 

Hawai‘i State 1,108,229 1,211,537 1,360,301 211.8 

Source: U.S. Census Bureau 2010
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6.2.2 Housing 

Since 2000, Maui County’s strong local economy, low mortgage interest rates, and mainland 

investment in real estate, has spurred a huge demand in housing. Off-island buyers are largely 

contributing to the increased housing demand with nearly a fifth of the housing units in the County 

not inhabited by County residents. Within the County, the median household income in 2005 was 

$57,573, and the median housing value was $573,400. The Census Bureau estimated that Maui 

County residents paid an average of $24,204 per year in mortgage costs, consuming 42.04 percent of 

their income. The generally accepted definition of affordability is for a household to pay no more 

than 30 percent of its annual income on housing. Families who pay more than 30 percent of their 

income for housing are considered cost burdened and may have difficulty affording necessities such 

as food, clothing, transportation and medical care. The majority of Maui County residents are paying 

an unsustainably high percentage of their income toward housing (Maui County Planning 

Department (MCPD) 2006, MCPD 2010). 

Homelessness and the difficulties associated with finding affordable, legal, and safe housing are 

growing problems throughout Hawai‘i. According to the Homeless Service Utilization Report 

(2009), there were 1,115 people in homeless shelters in Maui County in 2009. Several service 

organizations throughout the County assist in providing emergency and transient housing. 

6.2.3 Education 

In 2005, the Census Bureau estimated that 86.6 percent of County residents age 25 or older have 

graduated high school and 23.8 percent have a bachelor’s degree or higher. While the high school 

graduation rate of Maui County is slightly higher than that of the remainder of the United States, the 

percentage of residents with higher-level degrees is lower. Up until 2009 Maui Community College 

was one of seven community colleges in the University of Hawai‘i System. In the spring of 2010, the 

Western Association of Schools and Colleges approved the name change from “Maui Community 

College” to “University of Hawai‘i Maui College” to provide a more accurate reflection of the 

college’s three baccalaureate degrees. The main 78-acre Maui campus is in Kahului, Maui with 

additional education centers located in Hāna, Maui and on the islands of Moloka‘i and Lana‘i. The 

student population numbered around 4,400 students in the spring semester of 2011. 

The City of Kīhei has three public elementary schools, one private elementary school, one public 

intermediate school, and one public high school. The Kīhei-Makena Community Plan (1998) 

identifies the elementary school environment as one of the most important problems facing the 

community, describing classrooms as “crowded, uncomfortable, and generally poor” (MCPD 1998, 

MCPD 2006). 

6.2.4 Economics 

The median household income for the Island of Maui in 2009 was $64,150. In 2007, the Census 

Bureau reported that Maui County was home to 2,111 businesses owned by “Native Hawaiians and 

Other Pacific Islanders.” Unemployment figures for the island in January 2011 were at 7.9 percent, 

almost double the 4 percent unemployment rate in 2005. The most recent income figures for 

communities near the Refuge are shown on the next page in Table 6.2 (MCPD 2006, DBEDT 2010, 

Census 2010).
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Table 6.2. Census Bureau estimated median and per capita income figures, 2009. 

Area Median Household 

Income 

Median Family 

Income 

Per Capita 

Income 

Kīhei $63,223 $75,926 $29,519 

Mā’alaea $64,875 $120,268 $51,259 

Maui County $64,150 $72,367 $29,121 

Source: U.S. Census Bureau 2010

The economy on Maui is largely based on tourism. As the second most popular Hawaiian Island 

behind O‘ahu, there were 1,932,357 visitors to the Island of Maui in 2009 with an average daily 

count of 41,608 people. The hotels and service industry employs the largest amount of Maui 

residents, with 17,836 jobs in 2009 bringing in $565,032,534 in wages. Major employers include: 

Town Reality of Hawai‘i, Grand Wailea Resort Hotel, and Hyatt Regency Maui Resort & Spa 

(DBEDT 2010). 

The main tourist attractions for Maui island visitors include: Maui Ocean Center, historic whaling 

town of Lahaina, the road to Hāna, Ka‘anapali beaches, Haleakalā National Park, and Kīpahulu. The 

areas surrounding Mā‘alaea Bay and coastal Kīhei, which have seen extensive development of resort 

hotels, condominiums, and other commercial structures, are particularly important sites for tourism. 

Recreational visits to Keālia Pond NWR also directly contribute to the local economy. Visitor 

expenditures include food, lodging, transportation, and other expenses while engaging in activities on 

the Refuge. Approximately 2,700 people visit the Refuge each year for bird watching, photography, 

EE, and various habitat restoration projects (Speakman 1978, CH2M Hill, Inc. 1997). 

Agriculture remains an important component of Maui’s economy. Top products in Central Maui 

(near Keālia Pond) include: bananas, cattle, flowers, hogs, nursery products, pineapples, sugarcane, 

taro, and vegetables. Hawai‘i Commercial & Sugar Company dominates the agriculture industry on 

the Island. They are looking to diversify with a study on producing advanced biofuels from 

sugarcane grown on Maui. The Office of Naval Research is budgeting $2 million annually for the 

project through 2015, with a focus on producing diesel and jet fuel from sugar (MCPD 2010, UH 

2010). 

The State of Hawai‘i is investing in the advanced commercial high technology sector on Maui. 

Specific areas of interest include information technology, telecommunications, biotechnology, and 

space science. Kīhei, which contains two high-technology centers, has become a prime location 

promoting the development of this sector. Both the Maui High Performance Computing Center and 

the Maui Research and Technology Center are important elements in promoting the State as a center 

for innovative technology and ensuring a competitive economy in the future. Maui is also an 

important center for advanced astronomical research. The Haleakalā Observatory was Hawaii's first 

astronomical research and development facility at the Maui Space Surveillance Site electro-optical 

facility where satellite tracking facilities are co-located with a research and development facility 

(MCPD 2010). 
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Chapter 7. Environmental Effects Analysis 7-1 

Chapter 7. Environmental Effects Analysis 

7.1 Overview of Effects Analysis

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

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

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

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

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

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

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

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

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

as not all management strategies affect each resource. 

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

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

addressed in the final section of this chapter. 

7.2 Terminology

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

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

Negligible. Resources will not be affected, or the effects will be at or near the lowest level of 

detection. Resource conditions will not change or will be so slight no measurable or 

perceptible consequence to a population, wildlife or plant community, recreation opportunity, 

visitor experience, or cultural resource will occur. 

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

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

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

and successful. 

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

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

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

and will be extensive, moderately complicated to implement, and probably successful. 

Major. Effects will be obvious and will result in substantial consequences to a population, 

wildlife or plant community, recreation opportunity, visitor experience, or cultural resource 

within the local area and region. Extensive mitigating measures may be needed to offset 

adverse effects and will be large scale in nature, very complicated to implement, and may not 
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7-2 Chapter 7. Environmental Effects Analysis

have a guaranteed probability of success. In some instances, major effects will include the 

irretrievable loss of the resource. 

Time and duration of effects have been defined as follows: 

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

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

season. 

7.3 Summary of Management Action Effects at Keālia Pond NWR

A summary of the effects analysis is presented in Table 7.1. Current management (Alternative A) 

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

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

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

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

current condition. 

Table 7.1. CCP Alternatives Summary of Effects for Keālia Pond NWR. 

EFFECTS TO WILDLIFE AND HABITAT

Alternative A Alternative B Alternative C

Effects to 

endangered 

ae‘o and 

‘alae 

ke‘oke‘o

Negligible. No change 

from current 

management. Refuge

continues to provide 

high quality wetlands 

supporting loafing, 

foraging, nesting, and 

chick-rearing 

appropriate to life

history needs. 

Minor to intermediate longterm positive effect. Increased 

predator control efficiency 

should decrease predation on 

young and adult birds yielding 

a greater number of young 

fledged. Increased foraging 

and loafing area for ae„o will 

become available with 

development of water source 

at Mā„alaea Flats and 

restoration.

Intermediate long-term 

positive effect. Increased 

predator control efficiency 

should decrease predation on 

young and adult birds 

yielding a greater number of 

young fledged. Increased 

foraging and loafing area for 

ae„o available with shallow 

water in main pond and 

development of water source 

at Mā„alaea Flats with

restoration. Minor long-term 

positive effects for „alae 

ke„oke„o as increased water 

sources provide breeding 

habitat during low water 

years.

Effects to 

seabirds

Negligible. No change 

from current 

management.

Negligible. No change from 

current management.

Minor long-term positive 

effect. Active pest vegetation 

management and outplanting 

native species will increase 

suitable nesting habitat.
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Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 7. Environmental Effects Analysis 7-3 

Alternative A Alternative B Alternative C

Effects to 

shorebirds 

Negligible. No 

change from current 

management. 

Minor to intermediate longterm positive effect. Increased 

predator control efficiency 

should decrease predation, 

increased foraging and loafing 

area will become available with 

development of water source at 

Mā‘alaea Flats with habitat 

restoration. 

Intermediate long-term positive 

effect. Increased predator 

control efficiency should 

decrease predation , increased 

foraging and loafing area 

available with low water in 

main pond over winter , and 

development of water source at 

Mā‘alaea Flats with habitat 

restoration. 

Effects to 

waterfowl 

Negligible. No 

change from current 

management. 

Minor long-term positive 

effects from wetland 

restoration. 

Negligible to minor short-term 

negative effects from reduced 

water coverage during winter at 

main pond. 

Effects to 

endangered 

‘īlio-holo-ika-uaua and 

honu ‘ea, 

and 

threatened 

honu 

Negligible. No 

change from current 

management. 

Minor long-term positive effect. 

Plant restoration in dune nesting 

areas and predator control 

should reduce erosion and 

decrease honu ‘ea and honu egg 

predation and harassment of 

‘īlio-holo-i-ka-uaua. 

Minor long-term positive effect 

with plant restoration in dune 

nesting areas. Predator control 

will decrease honu ‘ea and honu 

egg predation and harassment 

of ‘īlio-holo-i-ka-uaua. 

Fencing dunes facilitates 

restoration. 

Effects to 

endangered 

‘ōkai ‘aiea 

Negligible. Not 

currently managed. 

Negligible to minor long-term 

positive effect from removing 

pest plants around host species 

in dry coastal forest. 

Minor long-term positive effect 

from removing pest plants 

around host species and 

outplanting native host species 

in dry coastal forest. 

Effects to 

aquatic 

invertebrates

Negligible. No 

change from current 

management. 

Negligible. No change from 

current management. 

Minor short-term negative 

effect from low winter water 

coverage; higher salinity of the 

main pond will reduce 

invertebrate populations. 

Effects to 

native plants 

(incl. ‘ihi)

Negligible. No 

change from current 

management. 

Minor long-term positive effect 

with plant propagation and 

restoration projects. 

Intermediate long-term positive 

effect with habitat restoration 

efforts, removal of pest plants, 

and native plant species 

outplanting. 

 
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7-4 Chapter 7. Environmental Effects Analysis

Alternative A Alternative B Alternative C

Effects to 

wetland 

habitats and 

associated 

resident 

wildlife 

Negligible to minor 

long-term negative 

effects as growth of 

invasive plants will 

outpace maintenance 

efforts. Public use 

disturbance will 

remain about the 

same as at present. 

Minor long-term positive 

benefits to resident wetland 

bird species from an increase 

in wetland acreage with habitat 

restoration and water source 

development at Mā‘alaea 

Flats. Overall negligible effect 

due to minor positive effects 

from habitat improvements but 

negligible negative effects 

from new public use facilities 

that may increase disturbance. 

Minor long-term positive 

benefits to resident wetland 

bird species from an increase 

in wetland acreage with 

habitat restoration and water 

source development at 

Mā‘alaea Flats. Low water in 

main pond may have shortterm minor negative effects 

with reduced available habitat 

for some waterbirds. 

Effects to 

coastal dry 

forest and 

associated 

wildlife 

Negligible. No 

change from current 

management. 

Negligible. No change from 

current management. 

Minor long-term positive 

effect. Limited acreage will 

be restored with removal of 

kiawe. Native host plants will 

be outplanted and the habitat 

will become more suitable for 

endangered ‘ōkai ‘aiea. 

Effects to 

coastal 

strand/dune 

habitat 

Negligible. No 

change from current 

management. 

Minor long-term positive 

effect. Plant restoration should 

reduce erosion. 

Intermediate long-term 

positive effect with habitat 

restoration efforts, increased 

native species outplanting, 

and fencing to facilitate 

restoration of impacted dunes. 

Effects to offshore 

Molokini Islet 

habitat

Negligible. No 

change from current 

management.

Negligible. Intermediate long-term 

positive effect with habitat 

restoration efforts, removal of 

pest plants, and native plant 

species outplanting.

EFFECTS TO NON-NATIVE PREDATORS AND NON-TARGET SPECIES 

Effects of 

predator 

control 

Negligible. No 

change from current 

management. 

Negligible to minor localized 

reduction of mongooses, rats, 

dogs, and cats. 

Minor long-term positive 

effect. Enhanced water 

management will reduce 

predator habitat and 

concentrate trapping efforts. 

Effects of 

predator 

control to 

non-target 

species 

Negligible. Nontarget 

species are released 

unharmed at capture 

site. 

Negligible. Use of more 

efficient traps has produced no 

mortalities of non-target 

species. Non-target species are 

released unharmed at capture 

site. 

Negligible. Use of more 

efficient traps has produced 

no mortalities of non-target 

species. Non-target species 

are released unharmed at 

capture site. 

 
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Chapter 7. Environmental Effects Analysis 7-5 

PHYSICAL ENVIRONMENTAL EFFECTS 

Effects to air 

quality

Negligible. Sporadic 

dust plumes are a 

nuisance to adjacent 

neighbors. 

Department of Health 

has determined no 

health hazard. 

Minor long-term positive 

effects of increased water 

capability will reduce 

occurrences of dust plumes. 

Intermediate long-term positive 

effects of increased water 

capability will reduce 

occurrences of dust plumes. 

Effects to 

water quality

No change from 

current management. 

Minor long-term 

positive effects in 

reduction of turbidity 

due to water 

management. 

Minor long-term positive 

effects in reduction of turbidity 

as a result of wetland 

management, sediments settle 

in the pond before reaching the 

ocean. Breach of the sand plug 

is part of the natural cycle 

during high water events. 

Negligible short-term effects 

during chemical application. 

Minor long-term positive 

effects in reduction of turbidity 

as a result of wetland 

management, sediments settle 

in the pond before reaching the 

ocean. Breach of the sand plug 

is part of the natural cycle 

during high water events. 

Negligible short-term effects 

during chemical application. 

Effects to 

hydrology 

Negligible. No 

change from current 

management. 

Potential for minor long-term 

positive effects as a storm water 

retention basin. 

Potential for minor long-term 

positive effects as a storm water 

retention basin. 

Effects to 

visual quality 

Minor long-term 

positive effects by 

retaining more 

natural open space 

next to the bay. New 

Refuge facilities are 

sited and designed to 

blend in with the 

natural environment. 

Minor long-term positive 

effects by retaining more 

natural open space next to the 

bay. New Refuge facilities are 

sited and designed to blend in 

with the natural environment. 

Minor long-term positive 

effects by retaining more 

natural open space next to the 

bay. New Refuge facilities are 

sited and designed to blend in 

with the natural environment. 

EFFECTS TO CULTURAL AND HISTORIC RESOURCES

Effects to 

cultural and 

historic 

resources 

Negligible. No 

change from current 

management. 

Minor long-term positive 

effects from proactive measures 

taken for identification and 

protection of cultural resources 

(e.g., Molokini survey). 

Negligible to minor short-term 

potential for negative effects 

from: wetland restoration work; 

upland restoration disking 

associated with crops and moist 

soil management; and increased 

trails and public facilities. 

Minor long-term positive 

effects from proactive measures 

taken for identification and 

protection of cultural resources 

(e.g., Molokini survey). 

Negligible to minor short-term 

potential for negative effects 

from: wetland restoration work; 

upland restoration disking 

associated with crops and moist 

soil management; and increased 

trails and public facilities. 

 
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SOCIAL AND ECONOMIC EFFECTS 

Overall 

visitation 

Negligible. Minor 

rise in visitation 

due to 

demographic 

trends; rising 

demand for 

outdoor recreation; 

and some Refuge 

actions to improve 

facilities and 

programs. 

Minor long-term positive 

effects to visitation will result 

with restoration of additional 

wetland acres. 

Intermediate rise in visitation 

due to demographic trends; 

rising demand for outdoor 

recreation; and Refuge actions 

to improve facilities and 

programs. 

Minor to intermediate longterm positive effects to 

visitation will result from 

increased habitat management 

capabilities and increased 

waterbird use. Intermediate 

rise in visitation due to 

demographic trends; rising 

demand for outdoor 

recreation; and Refuge 

actions to improve facilities 

and programs. 

Prospects for 

wildlife 

observation and 

photography

Negligible. No 

change from 

current 

management. 

Minor long-term positive 

increase in opportunities and 

additional subjects associated 

with habitat restoration at 

Mā‘alaea Flats. 

Minor long-term positive 

increase in opportunities and 

additional subjects associated 

with habitat restoration at 

Mā‘alaea Flats. 

Prospects for 

environmental 

education (EE)

Negligible. No 

change from 

current 

management. 

Minor long-term positive 

effect because of staffing 

strategies that could result in 

enhanced volunteer support for 

the program. 

Minor to intermediate longterm positive effect because 

of staffing, volunteer EE 

program, trail improvements, 

and interpretation 

improvements that could 

enhance the program. 

Prospects for 

interpretation

Negligible. No 

change from 

current 

management. 

Minor long-term positive 

effect because of staffing 

strategies that could result in 

enhanced volunteer support for 

the program. 

Minor to intermediate longterm positive effect because 

of staffing, more trained 

volunteers, trail 

improvements, and 

interpretation improvements 

that could enhance the 

program. 

Economic 

effects

Negligible. No 

change from 

current 

management. 

Minor short-term positive 

effect due to increased 

operational and visitor 

expenditures. 

Minor long-term positive 

effect due to increased 

operational and visitor 

expenditures. 

Effects to 

environmental 

justice

Negligible. No 

change from 

current 

management. 

Negligible to minor long-term 

positive effects on human 

health and the social 

environment. 

Negligible to minor long-term 

positive effects on human 

health and the social 

environment. 

 
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Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 7. Environmental Effects Analysis 7-7 

7.4 Effects Analysis 

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

strategies described in Chapter 2 on the physical, biological, and human environment. Adverse 

effects to fish and wildlife species and habitats are considered significant if: 

 An action will result in a substantial change in the amount or quality of available habitat for a 

wildlife species. For wintering waterfowl, migratory shorebirds or native resident wildlife, a 

substantial reduction in habitat resulting in a significant adverse impact will be defined as a 

reduction of 30 percent or more of the available acreage or 50 percent of the quality of habitat for 

these species within the Refuge; a significant beneficial impact will be defined as a 30 percent or 

greater increase in the quantity or 50 percent increase in the quality of habitat for wintering 

waterfowl, migratory shorebirds or native resident wildlife. 

 An action will result in a substantial adverse effect; either directly or through habitat 

modifications, on any Federal threatened endangered, candidate, or special concern wildlife or 

fish species. This will also include species listed threatened or endangered by the State of 

Hawai‘i. 

 A Refuge action causes mortality of greater than 30 percent of the state’s population of a species. 

7.4.1 Water Level Management Effects to Endangered Waterbirds 

The hydrology of Keālia Pond is the primary factor that impacts the biological and ecological 

functions and determines endangered waterbird use of the wetland. It is logical to assume the 

conditions that existed before civilization were natural flooding and dewatering; however, with the 

changes in land use above the Refuge, “natural” flooding is now limited to 3-4 months in winter, in 

most years, and extremely dry conditions during fall months. The variable water level can benefit 

endangered Hawaiian waterbirds but can also pose negative impacts if water delivery is unreliable or 

inconsistent in the timing. In most years, supplemental pumping during the driest months into the 

main pond prevented the pond from drying completely. We have attempted to replicate a 

hydrological cycle that will provide the seasonal requirements needed for ae‘o and ‘alae ke‘oke‘o, 

both of which have differing needs, and also promote the health of the wetland system. If the Refuge 

did not supplement water from brackish-water wells during the dry months, water level will be too 

low and suitable habitat will be lost. 

The current management (Alternative A) relies on the existing hydrological processes of flooding in 

winter months (typically December-March) followed by a natural decrease in water level in 

spring/summer (April-August). Typically starting in August, the Refuge supplements water in the 

main pond by pumping from brackish water wells until the first winter rains are received (DecemberJanuary). This seasonal cycle has shown to be effective in providing high water conditions during 

winter months for ‘alae ke‘oke‘o breeding and low water conditions for ae‘o breeding season, in 

addition to year-round foraging and resting habitat. The original wells (constructed in 1970) were 

replaced with new wells and new pumps are outfitted to enable better water control; however, these 

wells, even at peak performance, still have limitations. For example, if the main pond is devoid of 

water, it will not be possible to fill the pond to 100 percent water coverage in the middle of summer; 

natural seepage and evaporation exceed the input of water into the main pond. 

Our priority is to hold water, flood, and dewater the wetlands to optimize waterbird habitat 

throughout the year, and maintain a healthy wetland environment. The location of Keālia Pond 
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Draft Comprehensive Conservation Plan and Environmental Assessment 

7-8 Chapter 7. Environmental Effects Analysis

NWR at the base of the watershed poses both positive and negative effects on endangered waterbird 

habitat. While it is not feasible to restore wetlands to completely “natural” condition, the focus has 

been to accept the human changes made in the past and mitigate potential negative impacts in the 

future. 

Two of the three streams entering into the Refuge from the West Maui Mountains have been diverted 

to irrigate sugarcane fields. During the dry summer months, virtually all of the flow is used for 

irrigation purposes, and the drainage channels feeding the pond are dry. In the rainy winter season, 

however, silt-laden run-off from the upper watershed swells the pond to more than 450 acres, making 

it the largest remaining natural pond in the State. If the outlet to the bay fails to open naturally, water 

is backed up in the channel and floods the highway and adjacent land. This occurred in January 1971 

when a short but intense period of rainfall inundated N. Kīhei Rd. to a depth of 1-2 feet. 

The intermittent flooding and siltation has created shallow and flat areas and expanses of open water 

which provide suitable resting, feeding, and nesting habitat for endangered waterbirds. Over half of 

the Refuge property is comprised of wetland habitat that is dependent on upper watershed streams. 

Given the current conditions, any level of management within the wetlands will have impacts to the 

endangered waterbirds. Ae‘o and ‘alae ke‘oke‘o have different habitat needs that may have 

coincided in the past, but require manipulation in the present. If no management is performed there 

is a high probability that many areas will be completely encroached by pest plant species and water 

will not be available year-round. With localized pest plant control, supplemental pumping during the 

driest period (September-December), and predator control, habitat is available for both ‘alae 

ke‘oke‘o and ae‘o throughout their life history. 

Alternative A: During wet years, there will be limited endangered ae‘o habitat at the main pond due 

to little or no exposed flats, but favorable habitat for ‘alae ke‘oke‘o. Mā‘alaea Flats will provide 

shallow water habitat for ae‘o. This habitat will likely dry out before ae‘o chicks could fledge in midsummer. The main pond will provide good ae‘o habitat during a moderately dry winter, however, 

Mā‘alaea Flats will remain dry. There will be limited endangered waterbird habitat during the 

summer except at constructed ponds and where pumped water is discharged into the main pond. 

Alternative B: There will be more ae‘o and ‘alae ke‘oke‘o habitat during wet winters due to habitat 

restoration. During dry years the effect on ae‘o and ‘alae ke‘oke‘o will be similar to Alternative A, 

but with additional habitat at Mā‘alaea Flats from a developed water source. 

Alternative C: Increased water sources will create greater ae‘o and ‘alae ke‘oke‘o habitat than 

Alternative B during wet winters. A proposed water control structure at the N. Kīhei Rd. bridge 

would provide more controlled release of water from the main pond to reduce flooding of ‘alae 

ke‘oke‘o nests. In dry years, the main pond will receive supplemental pumping to create shallowwater habitat that is suitable for ae‘o, but less so for ‘alae ke‘oke‘o. Development of water 

resources and the capability to manage water will allow the Refuge more options for enhancing 

wetlands based on waterbird requirements and also increase options to control nuisance issues. 

7.4.2 Effects of Management Actions to Migratory Birds 

Keālia Pond NWR is host to hundreds of migratory waterfowl and shorebirds from August-April. A 

much smaller number of migratory shorebirds are present year-round (typically juvenile birds). In 
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managing the Refuge for the benefit of endangered Hawaiian waterbirds, we are indirectly providing 

resting and foraging habitat for migratory birds. Similar to native waterbirds, the presence of 

migratory species is dependent on the water level and distribution and varies from year to year. 

Shorebirds 

Alternative A: During wet years, there will be limited shorebird habitat at the main pond due to 

little or no exposed flats. However, Mā‘alaea Flats will provide shallow water habitat for shorebirds. 

Habitat use often is high during the fall before the winter storms. The main pond will provide good 

shorebird habitat during a moderately dry year, however, Mā‘alaea Flats will remain dry through 

much of the shorebird wintering period. 

Alternative B: There will be more shorebird habitat during wet winters due to habitat restoration. 

However, during dry years the effect to shorebirds will be similar to Alternative A, but with 

additional habitat at Mā‘alaea Flats from a developed water source. 

Alternative C: Shorebird habitat will be greater than Alternative B. Increased habitat restoration 

will create shallow water habitat during wet winters. In dry years, the main pond and Mā‘alaea Flats 

will provide dependable shorebird habitat through the development of additional water sources. 

Waterfowl 

Alternative A: There will be negligible effects as this option assumes no change in current 

management programs. In a wet year, water will be high during the winter and slowly drop to about 

80-90 percent coverage by May. Water will continue to drop often to less than 20 percent coverage 

by September. Supplemental water is pumped from late summer until the first winter storm. 

Pumping capacity is insufficient to maintain a full pond. During dry winters, the main pond may 

remain half full with no water along the vegetated wetlands. Few waterfowl will use the main pond. 

At constructed ponds, a portable pump provides a dependable source of water throughout the year. 

This area is open to the public and may result in human disturbance to waterfowl. Vegetation control 

will occur during the dry season. Due to moist subsurface conditions, use of heavy equipment is 

frequently limited and pest plants continue to invade the wetlands. Waterfowl will continue to use 

the main pond and existing small ponds and flats during wet years. 

Alternative B: The Refuge will continue habitat management as in alternative A, but increase the 

level of habitat restoration within the vegetated wetlands. During wet years, waterfowl will use the 

restored wetlands as well as the main pond and adjacent vegetated shoreline for minor positive 

effects. In dry years the effect on waterfowl will be similar to Alternative A. 

Alternative C: The Refuge will increase its vegetation control efforts under this alternative. A 

water control structure will be constructed at the N. Kīhei Rd. culvert and additional ground water 

sources will be developed to result in minor to intermediate long-term positive effects. Water 

coverage in the main pond will be maintained at 20-30 percent from December-February. Although 

there will be improved habitat for waterfowl, these areas will be dry for about two-thirds of period 

when they winter at Keālia Pond. The last waterfowl usually departs in April, but large numbers 

depart in March. 

 
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Seabirds 

Alternative A: There will be no change to management. Management of Molokini would be a 

continuation of the previous stewards, DLNR, as a seabird colony with no public access. Monitoring 

and banding of seabird chicks would be maintained at the same level of 1-2 visits per year. 

Alternative B: Negligible short-term effects to seabirds are anticipated from one additional trip per year 

for bird banding and outplanting native species. 

Alternative C: Minor long-term positive effects are projected for seabirds at Molokini with active pest 

vegetation management and outplanting native species to increase suitable nesting habitat. Negligible 

short-term effects to seabirds are anticipated from two additional bird banding/outplanting trips per year. 

7.4.3 Effects to Sea Turtles and ‘Īlio-holo-i-ka-uaua 

Management activities associated with protecting 

threatened honu and endangered honu ‘ea will 

continue to be a collaborative effort between A&B 

Properties and the Refuge to construct and maintain 

fencing along N. Kīhei Rd. The original wood and 

wire fence was installed in 1997 and replaced 

numerous times throughout the 15 years. Within all 

alternatives, the original fence will be replaced, in 

total, by the recycled-plastic fence that has shown to 

prevent nesting females from entering onto N. Kīhei 

Rd. Maintenance of the new fence takes less time 

and cost than the annual replacement efforts of the 

original fence. 

Under Alternatives B and C, efforts will move towards restoration of dune habitat that includes 

native outplanting to stabilize the dunes for the benefit of nesting honu ‘ea and possibly basking honu 

or ‘īlio-holo-i-ka-uaua. In Alternative C, if implemented, a more rigorous effort will be made to 

restore dunes along the 2.75-mile beach and aim towards acquisition (or other form of land 

protection such as a conservation easement) from A&B Properties for the dune system extending 

from the Keālia Coastal Boardwalk to the west side of Mā‘alaea Flats. Management responsibility of 

the coastal dunes along Mā‘alaea Flats will enable the Refuge to enforce the no camping and off-road 

vehicle use. This protection will also help protect the inland flats used by endangered and migratory 

birds. 

7.4.4 Effects to ‘Ōka‘i ‘aeia 

The necessary biological requirements of ‘ōka‘i ‘aeia adults for foraging, sheltering, dispersal, 

breeding, and egg production are native, nectar supplying plants, and the dry to mesic habitats 

between the elevations of 0-5,000 ft and receiving between 10-100 inches of annual precipitation 

which currently support or historically have supported these plants. Although only a few ‘ōka‘i ‘aeia 

have been reported at Keālia Pond, the Refuge has the potential to meet these requirements for both 

adult and larvae. A closely associated State wetland management area, Kanaha Pond, is identified as 

New fence Laura Beauregard/USFWS
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such habitat. Any restoration efforts to remove pest plants such as kiawe trees and outplant host 

species for ‘ōka‘i ‘aeia will have positive effects to meet its habitat needs. 

Alternative A: There will be no change to management. 

Alternative B: Pest plant removal such as kiawe and Indian marsh fleabane from potential host 

plants will have a localized minor positive effect. 

Alternative C: Pest plant removal such as kiawe and Indian marsh fleabane from potential host 

plants will have a localized minor positive effect. Restoration and outplanting of native host species 

could have an intermediate long-term positive effect. 

7.4.5 Effects to Aquatic Invertebrates

Aquatic invertebrates are known to be food resources for waterbirds. Aquatic invertebrates will 

benefit from all alternatives; however, the abundance and diversity of species will be greater for 

Alternatives B and C as wetland enhancement and water management capabilities are attained. 

Invertebrate composition and relative abundance is reliant on abiotic parameters (temperature, 

salinity, dissolved oxygen, turbidity, pH) and a function of the periodicity and level of water in the 

wetlands. The EPA has determined that the chemical methoprene exhibits low toxicity to non-target 

organisms. 

Alternative A: Under this alternative, midge emergences will reach nuisance levels when the main 

pond nearly dries out in summer/fall and it becomes full from winter storms. However, if the pond 

fills to about 40-50 percent from winter storms, an outbreak will not likely occur. If the pond does 

not dry out during the summer/fall and remains full the following winter, midge emergences will 

remain at moderate levels. 

Alternative B: Conditions for midge emergence level will be similar to Alternative A. Habitat 

restoration will also produce a diverse population of other invertebrate that will be beneficial to 

waterbirds in a wet winter. 

Alternative C: By controlling winter water level during the winter, midge emergence will remain at 

moderate levels. 

7.4.6 Control of Pest Plant Species and Native Plant Restoration 

The Refuge’s plant communities consist primarily of nonnative pest plants that existed before the 

Refuge was established in 1992 and which pose one of the greatest threats to endangered waterbirds. 

Because the target species are located in flooded areas, access to the areas is difficult and only a 

small window of opportunity exists when the soils are dried sufficiently to withstand the weight of 

heavy equipment. Although access by foot is possible, hand removal of monotypic areas of pest 

plants is not feasible, realistic, or time/cost efficient. The Refuge relies on mechanical treatment to 

control pest plants. Controlling pest plants is a continuous need due to the year-round growing 

season. Under all alternatives, these management actions are expected to have minor to intermediate 

positive effects to the habitat. 
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Alternative A: There will be no change to management. 

Alternative B: Pest plant removal in each habitat will have localized minor positive effects. 

Propagation of native plants and outplanting projects will have minor long-term positive effects in 

the restoration of healthy native plant communities on the Refuge. 

Alternative C: The Refuge will increase its vegetation control efforts and initiate native plant 

restoration on Molokini. Intermediate long-term positive effects are anticipated from this alternative.

7.4.7 Predator Control Effects 

Predator controls are implemented to reduce depredation of endangered waterbirds. Control 

measures will include indirect, non-lethal and lethal techniques in addition to prevention measures 

that will have minimal effects on the human environment. 

Indirect Measures 

Indirect measures at Keālia Pond NWR will include installation of a perimeter predator proof fence 

(Alternative C). In the absence of this fence, dense vegetation will remain to discourage visitors 

from disturbing endangered waterbirds and nesting areas will be temporarily closed to access. Cattle 

egret roost trees will be mechanically removed or treated with herbicides. 

Direct Measures 

A range of predator management equipment and methods will be used on the Refuge. All control 

management activities will be in compliance with Federal and State laws and regulations. Most cats 

and dogs will be removed by cage traps and transported to an animal shelter. Mongooses and rodents 

will be controlled by a combination of cage traps, lethal traps, and rodenticides. Direct control of 

cattle egrets will be with firearms. In rare instances a Timms TM kill trap (a type of snap trap) or 

padded leg-hold trap will be used on cats that avoid cage traps. All cage traps will be checked every 

48 hours or less. Except for continuous trapping (year-round) near the Refuge headquarters, trapping 

will occur seasonally just prior to the ae‘o nesting season through the end of the breeding/chick 

rearing period (April-September). Spot trapping may occur when signs of depredation of endangered 

species are observed outside the nesting season. 

Predator monitoring will occur throughout the year by direct observations, tracks, tracking tunnels, 

and trail cameras. Cage-trapped dogs and cats will be transported to a local animal shelter. Any 

cage trapped birds will be released at the trap site. Live trapped mongooses will the euthanized using 

approved humane methods. Except for nuisance pest species, all uninjured non-target species 

captured will be released near the site of capture or at a suitable location at the discretion the Refuge 

staff. 

Most of Keālia Pond NWR is closed to the public and posted. In public access areas (Kanuimanu 

Ponds and Keālia Coastal Boardwalk), most predator control measures will be conducted during the 

ae‘o nesting season and areas with active nests will also be closed. Rodenticides will be placed in 

tamper resistant bait boxes and the area signed, complying with all label directions. Herbicide 

treatment of cattle egret roost trees will occur in closed areas of the Refuge. Egret control by 

firearms will occur when the Refuge is closed to the public. 
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Other Alternatives Considered

Alternative methods for addressing predation of listed species on the Refuge were considered, 

including: non-lethal control only, indirect control only, and no predator management. 

The proposed predator management plan combines direct actions to control predation along with 

indirect actions related to reduced disturbance and improved habitat quality. The Service believes 

this proposal represents the most effective and most humane alternative. 

A non-lethal method will be ineffective against rats. The Refuge attempted to live trap rats with no 

success. Cage traps have been used for mongooses in the past, but when New Zealand Department 

of Conservation (DOC) 250TM snap traps were paired with cage traps, nearly all mongooses were 

caught in the DOC traps. Thus, the Refuge will be increasing use of the DOC traps to remove 

mongooses. 

The Refuge has used indirect control by vegetation removal around nesting areas, but trapping results 

and reproductive success data shows that it is insufficient to meet predator control objectives. Use of 

predator fences will help, but budget constraints limit their acquisition and installation. In addition to 

cost for materials, a predator fence will require high maintenance cost to maintain the corridor clear 

of vegetation (debris from upper watershed sheetflow, fallen trees). Once fenced, predators must be 

removed from the enclosed area. It may be practical in selected areas, but not all high-density 

nesting sites. Predator-proof fences do not guarantee 100 percent exclusion of predators and must be 

continuously monitored. 

The option of not performing predator control is not realistic with objectives to protect endangered 

waterbirds with the potential for increasing population numbers and delisting or removing them from 

endangered status. When the Refuge was first staffed in 1994, predator control was not conducted 

resulting in low reproductive success of endangered waterbirds. Currently, only a small portion of 

the Refuge is targeted for predator control, but there is a several fold increase in endangered 

waterbird reproductive success in the treated areas compared to control areas. 

The Recovery Plan for the Hawaiian waterbirds states that long-term predator management at nesting 

sites is needed. The regional shorebird conservation plan lists eradication or control of introduced 

predators among its management priorities. The Refuge predator control plan is intended to control 

species alien to Hawai‘i while native species would not be affected. Although predator management 

is a major component in the recovery of endangered Hawaiian waterbirds, recovery also requires 

management of a number of other factors including water, vegetation, pest plant species, and disease 

(Englis and Naughton 2004, USFWS 2005). 

Effects of Predator Control on Non-target Species 

Alternative A: There will be no change to predator management. Control efforts will continue to 

focus on public access areas of the Refuge throughout the year. Indirect, non-lethal and lethal 

techniques will be used. Most cats and dogs will be controlled by cage traps and transported to an 

animal shelter. Other predators will be controlled by cage traps or humane lethal means. Cattle egret 

roost trees will be mechanically removed or treated with herbicides. Egret control by firearms will 

occur when the Refuge is closed to the public. Past records show no loss of non-target native 

wildlife. There was a single isolated occurrence of a non-target nonnative species mortality by a 
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cage trap. All uninjured non-target species captured will be released near the site of capture or at a 

suitable location at the discretion of the Refuge Manager. 

During the ae‘o nesting season control efforts will be conducted at areas with high nest densities in 

both public access and closed areas. Rodenticides will be placed in tamper resistance bait boxes and 

the area posted with signs. No known non-target species mortalities have occurred from these baits. 

Alternative B: Predator control efforts will be expanded to high density nesting areas created by 

wetland restoration. However, trapping techniques will be similar except that proportionately more 

efficient traps will also be used. Perimeter trapping will be implemented. 

Alternative C: The ability to control water will restrict terrestrial predator habitats. Consequently, 

control efforts will be more concentrated and efficient during the ae‘o nesting season. Perimeter 

trapping will be increased. However, trapping techniques will be similar to alternative B. The effect 

to non-target species is not expected to change. 

7.4.8 Effects of Management Actions to Restore Coastal Dry Forest Habitat 

Alternative A: No management actions are planned under Alternative A. 

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

Limited native plant species will be protected and limited pest plants removed. 

Alternative C: Implementation of Alternative C will result in an intermediate long-term positive 

effect. Maximum acreage will be restored under this alternative. Native plants will be planted and a 

greater effort made to control pest plants and restore the natural dry forest habitat. Minor clearing 

will occur to survey areas proposed for expanding the northern boundary of the Refuge. 

7.4.9 Effects of Management Actions on Coastal Strand/Dune Habitat 

Low intensity management on beach and dunes will include fencing, spot treatment of pest plants, 

and minimizing predator disturbances. Semi-annual beach clean-ups will be coordinated with 

volunteers. Removing marine debris from the coastal zone is an important step to prevent 

entanglement and ingestion by honu, marine mammals, and migratory birds. Positive effects are 

anticipated to be minor to intermediate in Alternatives B and C. 

7.4.10 Effects to Offshore Islet Habitat and Seabirds 

Molokini Islet is currently protected by the U.S. Government through administration by the USCG; 

however, it is not actively managed for wildlife conservation. Most offshore islands of the State of 

Hawai‘i are owned by the State and are designated State Wildlife Sanctuaries. These offshore 

islands are minimally managed due to the State’s inability to provide adequate resources for 

maximum protection. 

There is no immediate threat of destruction or development on Molokini. The main threat to the islet 

is unauthorized human and pet trespass. Thus, there is a high probability of more pest species 

including mongooses, rats, mice, cats, ants, and plants. 
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The Service is proceeding with the establishment of Molokini Islet as an overlay Refuge unit 

administered by the Maui NWRC office with ownership retained with the USCG. Management and 

eventual ownership of Molokini by the Service will provide a continuum of public ownership for the 

offshore islands of the State and will increase the biodiversity of Molokini and assist the State in 

meeting wildlife and habitat goals. Under Service management in collaboration with the State, the 

island habitats and wildlife populations could be more readily restored. The waters adjacent to the 

island are designated as a Marine Life Conservation District under the administration of DLNR and 

patrolled by the State for marine safety, fishing violations and associated land trespass on Molokini. 

All Alternatives: All alternatives include establishment of Molokini as an overlay Refuge unit; 

however, the differences between the alternatives is with the level of inventory and monitoring (site 

visits), and native plant restoration. Under Alternative A, management will be a continuation of the 

State’s program which includes 1-2 visits per year to band ‘ua‘u kani chicks October-November for 

tracking and data collection. Colored leg bands on are usually hard plastic with etched codes. This 

minimal level of monitoring and banding will maintain consistency in collection of data. Public 

benefits will accrue in the form of natural resource protection of seabirds and plants for the benefit of 

future generations. A limited volunteer program to assist with native plant propagation will provide 

limited hands-on opportunities to Refuge volunteers. 

Alternative B: The Refuge will maintain the same 1-2 visits per year to band ‘ua‘u kani chicks and 

an increase to 3 visits per year will allow Biologists to monitor ‘ua‘u kani breeding pairs. This 

monitoring effort will be a template on which to gauge success and management needs for Maui’s 

‘ua‘u kani colonies. The result will have minor long-term positive effects. 

Alternative C: ‘Ou are known to nest on Molokini; however, the importance of Molokini to these 

lesser seen burrowing seabirds is unknown. Under Alternative C, the Refuge and DLNR staff will 

implement annual visits specifically to identify the breeding phenology and number of pairs. The 

Refuge will evaluate a banding program for ‘ou, but will implement a program only to the extent that 

there are no negative impacts to ‘ua‘u kani that arrive a couple/few months after ‘ou. 

The potential to restore the native plant community on Molokini to a natural community similar to a 

survey conducted in 1913 (the earliest record) is of interest by the Service, DLNR, and the Offshore 

Island Restoration Committee. The endangered ‘ihi is present on Molokini as well as other native 

species. Its isolation from the other islands, closure to public access, and implementation of 

measures to prevent introduction of pest species (e.g., freezing clothes and equipment) provide 

potential for successful restoration. The result will have intermediate long-term positive effects for 

native plants as well as seabird populations. 

7.4.11 Effects of Promoting Research and Scientific Assessments 

Being able to compare Refuge data with other local, regional, and even global data will help guide 

ecosystem management priorities for Refuge resources. It will also promote the Service’s ecosystem 

approach to resource management, as well as enhance worldwide scientific connection and 

understanding. Under all alternatives, effects of promoting management-related research and 

scientific assessment will have minor to moderate long-term positive impacts on the Service’s ability 

to effectively manage the Refuge. 
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7.4.12 Effects to Water, Soils, and Air Quality 

The main pond is gradually being filled with water-borne and wind-borne sediments, and its holding 

capacity is therefore being reduced. It is believed that a dynamic equilibrium has been established, in 

which sediment inflow was approximately in balance with sediment loss. During the dry summer 

season, the pond’s water evaporates and seeps completely. Without a protective covering of water, 

the dried pond sediments are subject to wind erosion. The wind-caused annual deflation of the pond 

creates additional storage capacity for sediment deposition in the subsequent rainy season (Maciolek 

1971). 

The main pond has a maximum amount that can be held back behind the naturally formed sand berm. 

At approximately 4.3-4.7 ft. MLLW, the force of water on the backside of the sand plug is so great 

that the water breaches through and enters into the ocean. Depending on the amount of water being 

delivered to the pond through streams and precipitation, the sand plug will remain open. The pond’s 

ability to hold water is dependent on the elevation such that if suspended sediments from streams are 

added to the pond bottom, the result will be less capacity to hold large amounts of water before 

flooding occurs in advance of the sand plug breaching open. 

Methoprene is a widely used larvicide for pest control because of its negligible toxicity to vertebrates 

and other nontarget organisms and rapid degradation after application. See Appendix F for Section 7 

Consultation – Methoprene. 

Alternative A: There will be no change to management. Although sporadic dust plumes are a 

nuisance to adjacent neighbors, the Department of Health has determined no health hazard. The 

effects of water management reduce turbidity by allowing sediments to settle out of the water column 

thereby improving water quality. This alternative will have negligible effects. 

Alternative B: Minor long-term positive effects of increased water capability will reduce 

occurrences of dust plumes. The effects of water management reduce turbidity by allowing sediments 

to settle out of the water column thereby improving water quality. 

Alternative C: Intermediate long-term positive effects of increased water capability will reduce 

occurrences of dust plumes. The effects of water management reduce turbidity by allowing sediments 

to settle out of the water column thereby improving water quality. 

7.4.13 Effects to Cultural and Historic Resources 

Athens et al. (1996) concluded that it is not likely that cultural resources are present in the Keālia 

Pond area due to the site’s close proximity to an active beach and the nearness of the upper soil 

deposits to the water table. The most recent archaeological and cultural investigation occurred in 

2009 and was specific to 13 acres in the forested habitat along the entrance road prior to construction 

of the new HQ/VC. There is no pre-contact evidence within this area; however, the investigation 

confirmed the area was used for cattle ranching from the rock area with cattle troughs. The 

researchers did not find any new evidence of Hawaiian occupation within or adjacent to the Refuge. 

Alternative A: There will be no change to management. Prior to implementing all ground disturbing 

projects, the applicable cultural resource compliance investigation will be undertaken. If cultural 
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resources are found, appropriate procedures and protocols will be followed to protect the cultural 

resources. The effects to cultural resources is anticipated to be none to negligible. 

Alternative B: Minor long-term positive effects are anticipated by identifying cultural resources 

present on Molokini Islet. Identification will aid in protection of any cultural and/or archeological 

resources on the islet. 

Alternative C: Minor long-term positive effects are anticipated by identifying cultural resources 

present on Molokini. Identification will aid in protection of any cultural and/or archeological 

resources on the islet. 

7.4.14 Effects to Public Use and Access 

Minimizing disturbance to natural resources will be a critical factor in selecting locations for public 

use programs. Negligible short-term effects are expected because of the small footprint of the 

participants on any given day and the onsite guidance they will be provided. Long-term beneficial 

effects will be exposing students to opportunities to experience the outdoors and contribute to our 

knowledge base for the Refuge. Through these experiences participants will gain a greater 

appreciation for nature, wild places, environmental processes, and potentially guide them into a 

science career. The Refuge will benefit from the information gained that will contribute to more 

effective management of the biotic and abiotic components of this rare coastal community. 

Despite the anticipated increased level of visitor services, including EE and interpretation, public 

tours, wildlife viewing opportunities, and nature photography, effects are expected to be negligible 

with implementation of either Alternative B or C. When compared to other areas on Maui available 

for these activities, the consequences to wildlife by increases in public use opportunities at this 

Refuge will not be noticeable. 

The effects of visitor services programs to natural resources, endangered and non-endangered 

wildlife and plants, and migratory bird species is expected to be negligible as a result of the timing, 

seasonal access limitations, and limited access and areas available for public use on the Refuge. 

Keālia Pond NWR’s new HQ/VC is expected to attract many more visitors than previous years, 

particularly due to installation of signs along Mokulele Hwy. and inclusion into other agencies’ 

literature. 

Alternative A: Refuge staff will provide an intermediate increase in visitor opportunities just 

because there is a VC and direct point of contact. 

Alternatives B: Additional opportunities will be provided and EE and interpretation programs will 

be more regular. 

Alternative C: Additional opportunities will be provided and EE and interpretation programs will 

be more regular. We will evaluate and implement more opportunities to give special interest 

individuals and groups (e.g., photographers) better viewing opportunities, increase volunteer 

opportunities, and develop hands-on EE curricula. An additional trail (boardwalk) will be planned 

and designed for visitors to walk from the HQ/VC to Kanuimanu Ponds via the forest habitat. This 

will enable more people to access this area at one time. 
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7.4.15 Economic Impacts 

National wildlife refuges provide many services to people. A complete economic analysis of the 

Refuge System includes not only the value of all the forms of recreation enjoyed but also the payrolls 

of Refuge employees and the values of maintaining endangered species, preserving wetlands, 

educating future generations, and adding stability to our ecosystem. All of these services are of value 

to society, whether or not they result in some form of market transaction. Some people gain value 

simply from knowing that wild places and unique species still exist. 

If expenditures are from outside the region, it generates increased economic activity for the region. 

If it is from within the region and will have occurred in the region anyway, it does not increase 

economic activity but is important for local businesses. Thus it is important to separate spending by 

people from outside the Refuge's economic region from spending by those who live locally. Local 

residents will probably have spent their recreation money in the local economy with or without the 

Refuge. In contrast, non-residents may be been attracted to the area by the Refuge. They would 

have gone elsewhere except for its presence, and their spending is a stimulus to the economy. Nonresident spending generates new income and new jobs (Carver and Caudill 2007). 

Recreational visits to Keālia Pond NWR will continue to contribute to the local economy under all 

alternatives. Visitor expenditures include food, lodging, transportation, and other expenses while 

engaging in refuge recreation. As more people visit the Refuge each year for bird watching, 

photography, environmental education, and various habitat restoration projects, expenditures in the 

local community should have a corresponding increase (Caudill and Henderson 2005). 

7.4.16 Environmental Justice 

The concept of environmental justice has been around since the early 1990s and arose from a need to 

ensure that negative environmental activities from industry or government projects will not endanger 

local communities. The EPA oversees environmental justice compliance and defines environmental 

justice as: “the fair treatment and meaningful involvement of all people regardless of race, color, 

national origin, or income with respect to the development, implementation, and enforcement of 

environmental laws, regulations, and policies” (USEPA 2010). 

Since CCP implementation of any of the alternatives is expected to result in generally positive effects 

on the human environment, there will be little risk of disproportionate negative effects to low income 

or minority groups. Therefore, negligible effects related to environmental justice are anticipated 

under all CCP alternatives. 
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7.5 Cumulative Effects Assessment 

Cumulative impacts are the overall, net effects on a resource that arise from multiple actions. Impacts 

can “accumulate” spatially, when different actions affect different areas of the same resources. They 

can also accumulate over the course of time, from actions in the past, the present, and the future. 

Occasionally, different actions counterbalance one another, partially canceling out each other’s effect 

on a resource. But more typically, multiple effects add up, with each additional action contributing an 

incremental impact on the resource. In addition, sometimes the overall effect is greater than merely 

the sum of the individual effects, such as when one more reduction in a population crosses a 

threshold of reproductive sustainability, and threatens to extinguish the population. 

A thorough analysis of impacts always considers their cumulative aspects, because actions do not 

take place in a vacuum; there are virtually always some other actions that have affected that resource 

in some way in the past, or are affecting it in the present, or will affect it in the reasonably 

foreseeable future. So any assessment of a specific action’s effects must in fact be made with 

consideration of what else has happened to that resource, what else is happening, or what else will 

likely happen to it. 

7.5.1 Cumulative Climate Change Effects on Water Resources 

The future climate change impacts expected for Hawai‘i are warmer temperatures (air and ocean), more 

severe droughts and floods, and a rise in sea levels. Giambelluca et al. (2008) reported that air 

temperatures in Hawaii have increased at a rate of 0.3 ̊F/decade (0.16 ̊C/decade) since 1975, which is 

comparable to the rate of increase in global temperatures. Temperature observations at the Mauna Loa 

Observatory in Hawaii from 1977 to 2006 indicate a warming trend of 0.4 degrees F/decade. Rainfall 

intensity has reportedly increased 12 percent in Hawai‘i between 1958 and 2006 but total rainfall has 

decreased about 15 percent over the last 20 years. These changes have and will continue to affect biologic 

and water resources on Maui and the other islands (Oki 2004, Mimura et al. 2007, Turcotte and Malamud 

2009, Chu and Chen 2005, Fletcher 2010). 

While ENSO events have increased in intensity and frequency over the past decades, some longerterm records have not found a direct link to global warming and do not predict significant changes in 

ENSO; however, a majority of climate forecasts do suggest an evolution toward more “El Niño-like” 

patterns. Most climate projections reveal that this trend is likely to increase rapidly in the next 50 

years. However, other models predict more “La Niña-like” conditions in the Hawaiian Islands 

(Walther et al. 2002, Buddemeier et al. 2004, Timm 2008). 

A trend toward ENSO patterns will impact sea levels, sea temperatures, rainfall amounts, evaporation 

rates, and the occurrence of hurricanes; however, the exact impact of climate change on water 

resources is difficult to predict due to spatial variability. On a global scale, mean precipitation is 

anticipated to increase. Current climate models project that tropical Pacific and high latitude areas 

will experience increasing precipitation amounts, while precipitation is likely to decrease in most 

subtropical regions. A current trend toward this increase is supported by lowered salinity levels in 

both the mid- and high-latitude oceanic waters. If the opposite effect takes place, decreasing 

precipitation or increasing evaporation will further stress meager surface and groundwater resources. 

Lack of rain could lower the amount of freshwater lens recharge and decrease available water 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

7-20 Chapter 7. Environmental Effects Analysis

supplies. Reduced rainfall or increased evaporation will cause a corresponding increase in the 

demand for residential, commercial, or agricultural water (Giambelluca et al. 1986, Solomon et al. 

2007, Parry et al. 2007). 

 

An increase in heavy storms and surf will result in increased flood risks, sedimentation, and impeded 

drainage on Maui. In particular, the low-elevation Refuge wetlands will be vulnerable to changes in 

storm frequency, intensity, and directionality. These events have the potential to denude vegetation 

or affect the biogeochemistry of the wetlands. It is difficult to assess the relative threat of long-term 

changes in rainfall and runoff to Keālia Pond. Certainly declines in rainfall and runoff, including 

baseflow, would affect the water supply for the pond. Warmer air temperatures may mean warmer water 

temperatures, decreased dissolved oxygen, and greater evaporation. Nuisance issues of blowing dust and 

fish kills may also be expected to be more common. Presently, the water level record at Keālia Pond is 

not long enough to assess whether or not the frequency of dry conditions has already increased in 

response to warmer temperatures, increasing evaporation, and decreasing precipitation. However, any 

gradual, long-term changes in rainfall and stream inflow may be overshadowed by more immediate and 

direct changes in upstream regulation and diversion and land management practices. As will be discussed 

below, such changes have the potential to greatly modify pond hydrology and ecology. 

More severe flooding would also affect Keālia Pond in a number of ways. It may increase the frequency 

or severity of disturbance in the pond and may also increase sediment loads reaching the pond, which 

could affect water quality and pond bathymetry. More severe flooding would also underscore the 

hydrologic function of Keālia Pond with respect to ameliorating flooding and runoff to the ocean. The 

pond and surrounding area act as a buffer, capturing flood waters and holding them before they move into 

the ocean (either as surface flow or subsurface seepage). The wetland protects the adjacent beach and 

offshore coral reef ecosystem from deleterious effects of erosion, sedimentation, and eutrophication 

associated with flood waters. 

Sea level rise is expected to exacerbate inundation, storm surge, erosion, and other coastal hazards. 

Currently, ocean waters only occasionally reach Keālia Pond during high tides with large waves. The 

frequency of these events will likely increase due to rising seas levels. It’s also likely that Keālia beach 

may be more prone to erosion due to rising sea levels and higher storm surges. This may threaten habitat 

and infrastructure in the area. As lower elevation islets within the Hawaiian archipelago become 

inundated, Molokini Islet and others like it will have more importance as critical seabird nesting sites. 

7.5.2 Cumulative Effects to Mā‘alaea Bay 

Coral reefs are vulnerable to a wide variety of toxic substances. Siltation has the direct effect of 

smothering coral and other types of sedentary plants and animals. In addition, reduced water clarity 

has an impact on corals, algae, and other organisms that require sunlight for survival. Shallow reefs 

in Mā‘alaea Bay are almost totally overgrown by invasive seaweeds and fish stocks are in very poor 

condition. Data gathered by the Hawaii Coral Reef Assessment and Monitoring Program (CRAMP) 

found that among 60 reefs surveyed in Hawai‘i, Mā‘alaea ranked 54 in species richness, 35 in 

density, 49 in biomass, and 55 in diversity. Overfishing, agricultural operations, livestock grazing, 

boating activities, wastewater injection wells, construction debris, and storm water runoff are all 

suspected culprits for the degradation. Mā‘alaea has 12 condominium complexes with 600 residents, 

as well as a shopping center, restaurants, a commercial activity park and the Maui Ocean Center. The 

Maui Ocean Center and Maui Electric Co. have 2 permitted discharge points into the bay (Hamilton 

2010, CRAMP 2011). 
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Chapter 7. Environmental Effects Analysis 7-21 

The Refuge primarily uses two EPA-approved chemicals that were selected for their low-toxicity to 

non-target species and the environment. Methoprene, the insect growth inhibitor used to reduce 

nuisance midge populations, is rapidly metabolized in plants, yielding products that are further 

degraded to normal plant building materials. Schaefer and Dupras (1973) studied the persistence of 

methoprene in water and found that the half-life in field water was only about two hours and it has 

almost no detectable residues after 24 hours. We have determined that Refuge use of this product has 

a negligible effect on cumulative regional uses. 

Glyphosate (RoundupTM) is used for spot treatment of invasive plant species. According to the EPA, 

it has only small and transient effects on the soil microbial community, even when applied at greater 

than field rates. Glyphosate is rated least dangerous in comparison to other herbicides; it does not 

bioaccumulate and breaks down rapidly in the environment. Based on current data, EPA has 

determined that the effects of glyphosate on birds, mammals, fish and invertebrates are minimal. 

With no bioaccumulation in the plants and a short residual time, Refuge use of this product has a 

negligible effect on cumulative regional uses (EPA 1993). 

Keālia Pond functions as a siltation basin that helps not only to cut the flow of silt from pouring into 

Mā‘alaea Bay, it biologically filters chemicals and organic materials that would affect sea life of 

near-shore reefs. As evident by the degraded condition of the reefs, the natural functions of the 

wetland have a negligible effect on ameliorating the aggregate discharges into the bay. In 2009, Maui 

County received a grant from the National Oceanic and Atmospheric Administration to investigate 

the cause of coral reef degradation at Mā‘alaea Bay. The Service is currently working through the 

U.S. Coral Reef Task Force (CRTF) to help develop strategies to mitigate anthropogenic stressors on 

coral reef ecosystems throughout the United States. The Water & Air Quality Working Group of the 

CRTF is charged with developing, recommending, and seeking or securing implementation of 

measures necessary to reduce and mitigate coral reef ecosystem degradation due to the cumulative 

effects of water- and air-borne pollution. 

7.5.3 Cumulative Effects to Water Supply Quantity 

We have identified the need for a comprehensive hydrological assessment at Keālia Pond NWR to 

evaluate wetland needs and upper watershed land-use changes. Three streams drain from 56-square 

miles of the West Maui Mountain watershed above Waikapū town into Keālia Pond. These stream 

flows are unpredictable and uncontrolled. One additional stream, Pūlehu, drains a portion of 

Haleakalā into Keālia Pond but its flow is also infrequent and unpredictable. Preliminary data exists 

on the amount of surface water these streams deliver to Keālia Pond. Further assessment is also 

needed to determine evapotranspiration rates and the amount (acre-feet) of stream flow that is 

required to maintain water level at a suitable depth to manage for waterbirds throughout the year. 

7.5.4 Cumulative Effects to Local Traffic Density 

Refuge impacts on local traffic density were evaluated as part of the environmental assessment for 

construction of the HQ/VC in a separate document. It was determined that any change in current 

daily traffic volume would be extremely small and any effect would be immeasurable as Refuge 

traffic would be sporadic. Refuge management actions to improve turtle fencing (replacing wire slats 

with recycled-wood fence) will have a minor positive long-term effect of reducing turtle fatalities 

from motor vehicles along N. Kīhei Rd. 
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7-22 Chapter 7. Environmental Effects Analysis

7.5.5 Summary 

The Refuge staff is not aware of any past, present, or planned actions within the next 15 years that 

will result in a significant cumulative impact when added to the Refuge’s proposed actions, as 

outlined in the proposed alternatives. The actions proposed by the Refuge in this CCP are expected to 

contribute negligible negative effects to cumulative impacts of any resort or condominium 

development, agricultural operations, harbor expansion, and power generation projects. 

Recovery of endangered species must be coordinated on a broad regional scale to show progress. It 

is only through the cumulative efforts of many groups, conservation projects, and measures that we 

can effectively save these species. Research to close knowledge gaps which hinder efficient recovery 

projects should be encouraged, promoted and shared with all partners. The cumulative effects of 

Service management of the Keālia Pond NWR with the proposed Molokini Unit, in collaboration 

with other wildlife refuges managed by other Federal, State, and County agencies, and non-profit 

conservation groups will have long-term positive effects towards the recovery of endangered species. 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix A: Species List A-1 

Appendix A: Species Lists 

Animal Species 

Common Name Scientific Name Hawaiian Name 

Fish 

Australian mullet Chelon engeli 

Chinese catfish Clarias fuscus 

Hawaiian flagtail Kuhlia sandvicensis ‘Āholehole 

Hawaiian sleeper Eleotris sandwicensis O‘opu 

Liberty/Mexican molly Poecilia spp. 

Milkfish Chanos chanos ‘Awa 

Mosquitofish Gambusia affinis I‘a makika 

Mozambique tilapia Oreochromis mossambicus 

Redbelly tilapia Tilapia zilii 

Striped mullet Mugil cephalus ‘Ama ‘ama 

Tilapia Oreochromis macrochir 

Invertebrates 

American cockroach Periplaneta americana 

Anthomyiid fly Clunio littoralis 

Argentine ant Linepithema humile 

Asian swallowtail butterfly Papilio xuthus 

Asian tiger mosquito Aedes albopictus 

Australian ant Aphaenogaster longiceps 

Banana skipper Erionota thrax 

Bigheaded ant Pheidole megacephala 

Bilobed looper moth Megalographa biloba 

Black field earwig Nala lividipes 

Black saddlebags Tramea lacerata 

Black witch Ascalapha odorata 

Blackburn’s sphinx moth Manduca blackburni ‘Ōka‘i ‘aiea 

Brine fly Ephydra gracilis 

Caddisfly Cheumatopsyche pettiti 

Carpenter ant Camponotus variegatus (Fr. Smith) 

Chinese rose beetle Adoretus sinicus 

Click beetle Cardiophorus stolatus 

Click beetle Conoderus exsul 

Cockroach egg parasitoid Evania appendigaster 

Comperia wasp Comperia merceti 

Crane fly Styringomyia didyma 

Crayfish Procambarus clarkii ‘Ōpae pake 

Dark orange dart Ocybadistes ardea 

Darner dragonfly Anax junius 

Drone fly Eristalis tenax 

Dung beetle Aphodius lividus 

Ficus blister gall wasp Josephiella microcarpae 

Fiery skipper butterfly Hylephila phyleus 

Fire ant Solenopsis geminata 

Fly Anthrax koshunensis 

Flying earwig Hawaiian damselfly Megalagrion nesiotes 

Formosan subterranean termite Coptotermes formosanus 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

A-2 Appendix A: Species List 

Fragile forktail Ischnura posita 

German cockroach Blattella germanica 

Giant Hawaiian dragonfly Anax strenuus Pinao 

Globe skimmer Pantala flavescens 

Grass bagworm Brachycyttarus griseus 

Grass shrimp Neocaridina denticulate sinensis 

Grasshopper Atractomorpha cynensis 

Green darner Anax junius 

Greenbugs aphid parastoid Lysiphlebus testaceipes 

Ground beetle Stenolophus quinquepustulatus 

Guava moth Ophiusa disjungens 

Hawaiian blue butterfly Udara blackburni Koa pulelehua 

Hawaiian darner Anax strenuus 

Hawaiian midge Chironomus hawaiiensis 

Hawaiian pelagic water strider Halobates hawaiiensis 

Hawaiian prawn Macrobrachium grandimanus ‘Ōpae oeha‘a 

Hawaiian red shrimp Halocaradiana rubra ‘Ōpae‘ula 

Hawaiian skimmer Nesogonia blackburni 

Hover fly Eristalinus aeneus 

Hover fly Ornidia obesa 

Hover fly Syritta orientalis 

Kamehameha butterfly Vanessa tameamea Pulelehua 

Little fire ant Wasmannia auropunctata 

Mealybug ladybird Cryptolaemus montrouzieri 

Mexican leaf-roller Amorbia emigratella 

Monarch butterfly Danaus plexippus 

Midge Chironomus esakii 

Midge Polypedilum nubifer 

Milkweed aphid Aphis nerii 

Orange-black Hawaiian damselfly Megalagrion xanthomelas Pinapinao 

Oriental cockroach Blatta orientalis 

Oriental latrine fly Chrysomya megacephala 

Painted lady Vanessa cardui 

Papuana ant Solenopsis papuana Emery 

Passion butterfly Agraulis vanillae 

Peablue butterfly Lampides boeticus 

Powderpost beetle Amphicerus cornutus 

Rambur's forktail Ischnura ramburii 

Red admiral Vanessa atalanta 

Red-black False Blister Beetle Ananca bicolor 

Riparian earwig Labidura riparia 

Roseate skimmer Orthemis ferruginea 

Rove beetle Philonthus sp. 

Salt marsh water boatmen Trichocorixa reticulata 

Sevenspotted lady beetle Coccinella septempunctata 

Skimmer dragonfly Orthemis ferruginea 

Seed bug Ligyrocoris litigiosus 

Small cabbage white Pieris rapae 

Soldier beetle Caccodes oceaniae 

Sonoran carpenter bee Xylocopa sonorina 

Southern house mosquito Culex quinquefasciatus 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix A: Species List A-3 

Spotted-winged midge Polypedilum nubifer 

Stable fly Stomoxys calcitrans 

Syrphid fly Eristalinus arvorum 

Vermilion saddlebags Tramea abdominalis 

Water scavenger beetle Tropisternus sp. 

Wasp mimic Taeniaptera angulata 

Western honey bee Apis mellifera 

Western pygmy blue butterfly Brephidium exilis 

Yellow crazy ant Anoplolepis gracilipes (F. Smith) 

Mammals

Black rat Rattus rattus ‘Iole 

Cat Felis catus Pōpoki 

Dog Canis familiaris ‘Īlio 

Hawaiian monk seal Monachus schauinslandi ‘Īlio-holo-i-ka-uaua 

House mouse Mus musculus ‘Iole 

Indian mongoose Herpestes auropunctatus Manakuke 

Norway rat Rattus norvegicus ‘Iole 

Polynesian rat Rattus exulans ‘Iole 

Reptiles and Amphibians 

Brahminy blind snake Ramphotyphlops braminus 

Cane toad Bufo marinus 

Common house gecko Hemidactylus frenatus Mo‘o ‘alā

Green anole lizard Anolis carolinensis porcatus 

Green turtle Chelonia mydas Honu 

Hawksbill sea turtle Eretmochelys imbricate Honu ‘ea 

Red-eared slider Chrysemys scripta elegans 

Hawaiian Birds 

Black-crowned night heron Nycticorax nycticorax hoactli ‘Auku‘u 

Hawaiian coot Fulica alai ‘Alae ke‘oke‘o 

Hawaiian duck Anas wyvilliana Koloa maoli 

Hawaiian goose Branta sandvicensis Nēnē

Hawaiian stilt Himantopus mexicanus knudseni Ae‘o 

Short-eared owl Asio flammeus sandwichensis Pueo 

Migratory Birds 

Grebes

Eared grebe Podiceps nigricollis 

Pied-billed grebe Podilymbus podiceps 

Herons

Cattle egret Bubulcus ibis 

Great blue heron Ardea herodias 

Great egret Ardea alba 

Snowy egret Egretta thula 

Ibises

White-faced ibis Plegadis chihi 

Geese and Ducks

American wigeon Anas Americana 

Blue-winged teal Anas discors 

Brant Branta bernicla 

Bufflehead Bucephala albeola 

Cackling goose Branta hutchinsii

Canada goose Branta canadensis 
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Canvasback Aythya valisineria 

Cinnamon teal Anas cyanoptera 

Common goldeneye Bucephala clangula 

Common merganser Mergus merganser 

Eurasian wigeon Anas penelope 

Fulvous whistling duck Dendrocygna bicolor 

Gadwall Anas strepera 

Garganey Anas querquedula 

Greater scaup Aythya marila 

Greater white-fronted goose Anser albifrons 

Green-winged teal Anas crecca 

Lesser scaup Aythya affinis 

Mallard Anas platyrhynchos 

Northern pintail Anas acuta Koloa māpu 

Northern shoveler Anas clypeata Koloa mohā

Red-breasted merganser Mergus serrator 

Redhead Aythya Americana 

Ring-necked duck Aythya collaris 

Snow goose Chen caerulescens 

Tufted duck Aythya fuligula 

Tundra swan Cygnus columbianus 

Stilts 

American avocet Recurvirostra americana 

Shorebirds

Baird’s sandpiper Calidris bairdii 

Black-bellied plover Pluvialis squatarola 

Bristle-thighed curlew Numenius tahitiensis Kioea 

Common snipe Gallinago gallinago 

Curlew sandpiper Calidris ferruginea 

Dunlin Calidris alpina 

Greater yellowlegs Tringa melanoleuca 

Killdeer Charadrius vociferus 

Least sandpiper Calidris minutilla 

Lesser yellowlegs Tringa flavipes 

Long-billed dowitcher Limnodromus scolopaceus 

Marbled godwit Limosa fedoa 

Pacific golden plover Pluvialis fulva Kōlea 

Pectoral sandpiper Calidris melanotos 

Red knot Calidris canutus 

Red-necked stint Calidris ruficollis 

Ruddy turnstone Arenaria interpres ‘Akekeke 

Ruff Philomachus pugnax 

Sanderling Calidris alba Hunakai 

Semipalmated plover Charadrius semipalmatus 

Sharp-tailed sandpiper Calidris acuminata 

Short-billed dowitcher Limnodromus griseus 

Spotted sandpiper Actitis macularia 

Wandering tattler Heteroscelus incanus ‘Ūlilī

Western sandpiper Calidris mauri 

Wilson’s phalarope Phalaropus tricolor 

Whimbrel Numenius phaeopus 
Keālia Pond National Wildlife Refuge 

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Appendix A: Species List A-5 

Gulls

Bonaparte’s gull Larus philadelphia 

California gull Larus californicus 

Common black-headed gull Larus ridibundus 

Franklin’s gull Larus pipixcan 

Herring gull Larus argentatus 

Glaucous-winged gull Larus glaucescens 

Laughing gull Larus atricilla 

Ring-billed gull Larus delawarensis 

Terns

Arctic tern Sterna paradisaea 

Black tern Chlidonias niger 

Caspian tern Sterna caspia 

Common tern Sterna hirundo 

Gull-billed tern Sterna nilotica 

Least tern Sterna antillarum 

Raptors

Barn owl Tyto alba 

Northern harrier Circus cyaneus 

Osprey Pandion haliaetus 

Peregrine falcon Falco peregrinus 

Gallinaceous Birds

Black francolin Francolinus francolinus 

Gray francolin Francolinus pondicerianus 

Ring-necked pheasant Phasianus colchicus 

Migratory seabirds 

Bulwer’s petrel Bulweria bulwerii ‘Ou 

Black noddy Anous minutes melanogenys Noio 

Blue-gray noddy Procelsterna cerulean saxatilis 

Brown noddy Anous stolidus pileatus Noio kōhā 

Great frigatebird Fregata minor palmerstoni ‘Iwa 

Lesser frigatebird Fregata ariel 

Red-footed booby Sula sula rubripes ‘Ā

Wedge-tailed shearwater Puffinus pacificus ‘Ua‘u kani 

Non-Native Passerines 

African silverbill Lonchura cantans 

Chestnut munia Lonchura atricapilla 

Common myna Acridotheres tristis 

House finch Carpodacus mexicanus 

House sparrow Passer domesticus 

Japanese white-eye Zosterops japonicas 

Java sparrow Padda oryzivora 

Mourning dove Zenaida macroura 

Northern mockingbird Mimus polyglottos 

Northern cardinal Cardinalis cardinalis 

Nutmeg manikin Lonchura punctulata 

Orange-cheeked waxbill Estrilda melpoda 

Red avadavat Amandava amandava 

Red-crested cardinal Paroaria coronate 

Rock dove Columba livia 

Spotted dove Streptopelia chinensis 
Keālia Pond National Wildlife Refuge 

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Zebra dove Geopelia striata 

Plant Species 

Spiny amaranth Amaranthus spinosus Pakai kuku 

Australian saltbush Atriplex semibacatta 

Pickleweed Batis maritima ‘Akulikuli kai 

Saltmarsh bulrush, makai sedge Bolboschoenus maritimus Kaluhā 

California grass Brachiaria mutica 

Ironwood Casuarina equisetifolia 

Buffel grass Cenchrus ciliaris 

Swollen fingergrass Chloris barbata 

Lead tree Cordia subcordata Kou 

Bermuda grass Cynodon dactyron Manienie 

Purple nutsedge Cyperus rotundus 

Smooth flatsedge Cyperus laevigatus Makaloa 

Salt grass Distichlis spicata 

Wild millet, jungle-rice Echinochloa colona 

Barnyard grass Echinochloa crus-galli 

Spikerush, bent spikerush Eleocharis geniculata 

Hawaiian cotton Gossypium tomentosum Mao 

Seaside heliotrope Heliotropium curassavicum Kīpūkai 

Hibiscus Hibiscus tiliaceus Hau 

Beach morning glory Ipomoea pes-caprae Pōhuehue 

Sprangletop Leptochloa fusca 

Koa haole Leucana leucocephala Koa haole 

Primrose willow Ludwigia octovalvis 

Hawai'i desert-thorn Lycium sandwicense ‘Ohelo kai 

False sandalwood Myoporum sandwicense Naio 

Tree tobacco Nicotiana glauca 

Screw pine Pandanus tectorius Hala 

Guinea grass Panicum maximum 

Hilo grass Paspalum conjugatum 

Seashore paspalum Paspalum vaginatum 

Marsh fleabane Pluchea x fosbergii 

Marsh fleabane Pluchea indica 

Marsh fleabane Pluchea carolinensis 

Mesquite Prosopis pallida Kiawe 

Coast sandalwood Santalum ellipticum Ihiahialo‘e 

Beach naupaka Scaevola sericea Naupaka kahakai 

California bulrush Schoenoplectus californicus ‘Aka‘akai 

Sea purslane Sesuvium portulacastrum ‘Akulikuli 

Yellow ilima Sida fallax ‘Ilima 

Seashore rushgrass Sporobolus virginicus ‘Aki’aki 

Beach vitex Vitex rotundifolia ‘Uhaloa 

Uhaloa Waltheria indica ‘Uhaloa 

 
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Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix A: Species List A-7 

Molokini Islet Species 

Common Name Scientific Name Hawaiian Name 

Invertebrates (2006)

American cockroach Periplaneta Americana 

Beet webworm Spoladea recurvalis 

Bigheaded ant Pheidole megacephala 

Black house ant Ochetellus glaber 

Black cockroach wasp Dolichurus stantoni 

Dark comb-footed spider Steatoda grossa 

Garden spider Argiope appensa 

Grass webworm Herpetogramma licarsisalis 

Guava moth Ophiusa disjungens 

Hawaiian carpenter ant Camponotus variegates 

House fly Musca domestica 

Jumping plant louse Heteropsylla cubana 

Keyhole wasp Pachodynerus nasidens 

Koa haole seed weevil Araecerus levipennis 

Long-legged fly Chrysosoma globiferum 

Narrow-winged mantis Tenodera angustipennis 

Orange-spotted ladybird Orcus australasiae 

Paperfish Ctenolepisma longicaudatum 

Sonoran carpenter bee Xylocopa sonorina 

Thrip Acrotelsa hawaiiensis 

Woodlouse spider Dysdera crocota 

Seabirds 

Bulwer’s petrel Bulweria bulwerii ‘Ou 

Black noddy Anous minutes melanogenys Noio 

Brown noddy Anous stolidus pileatus Noio kōhā 

Great frigatebird Fregata minor palmerstoni ‘Iwa 

Red-footed booby Sula sula rubripes ‘Ā

Wedge-tailed shearwater Puffinus pacificus ‘Ua‘u kani 

Plants (2005)

Hairy abutilon Abutilon grandifolium 

Goatweed Ageratum conyzoides 

Scarlet pimpernel Anagallis arvensis 

Prickly poppy Argemone glauca Pua kala 

Australian saltbush Atriplex semibaccata 

Saltbush Atriplex suberecta 

Spanish needles Bidens pilosa 

Alena Boerhavia herbstii Alena 

Alena Boerhavia repens Alena 

Buffel grass Cenchrus ciliaris 

Sandburr Cenchrus echinatus 

Hairy spurge Chamaesyce hirta 

Lambs quarters Chenopodium murale 

Swollen fingergrass Chloris barbata 

Radiate fingergrass Chloris radiata 

Feather fingergrass Chloris virgata 

Hairy horseweed Conyza bonariensis 

Swinecress Coronopus didymus 

Fuzzy rattlepod Crotalaria incana 
Keālia Pond National Wildlife Refuge 

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A-8 Appendix A: Species List 

Kaunaoa Cuscuta sandwichiana Kauna‘oa 

Beach wiregrass Dactyoloctenium aegyptium 

Spanish clover Desmodium sandwicense 

Henry's crabgrass Digitaria ciliaris 

Triangleleaf Lipfern Doryopteris decipiens ‘Iwa‘iwa 

Purple cudweed Gamochaeta pupurea 

Salt heliotrope Heliotropium curassavicum Nena 

Pili grass Heteropogon contortus 

Morning glory Jacquemontia ovalifolia subsp. 

sandwicensis 

Pā‘uohi‘iaka 

Prickly lettuce Lactuca sativa 

Lantana Lantana camara 

Koa haole Leucaena leucocephala Koa haole 

Coastal nehe Lipochaeta lavarum Nehe 

Hawai'i Desert-Thorn Lycium sandwicense ‘Ohelo kai 

Cow pea Macroptilium lathyroides 

Cheeseweed Malva parviflora 

Bur clover Medicago polymorpha 

Hairy morning glory Merremia aegyptia 

Sword fern Nephrolepis multiflora 

Tree tobacco Nicotiana glauca 

Indian fig Opuntia ficus-indica Panini 

Yellow wood sorrel Oxalis corniculata 

Panicum Panicum faurei subsp. latius 

Maui panicgrass Panicum pellitum Kaioio 

Torrid panicgrass Panicum torridum Ka kona kona 

Golden fern Pityrogramma austroamericana 

Sourbush Pluchea carolinensis 

Polycarpon Polycarpon tetraphyllum 

Ihi Portulaca molokiniensis ‘Ihi 

Pigweed Portulaca oleracea 

Portulaca Portulaca pilosa 

Purslane Portulaca sclerocarpa Po‘e, ‘ihi 

Pickleweed Sesuvium portulacastrum ‘Akulikuli 

Bristly foxtail Setaria verticillata 

Yellow ilima Sida fallax ‘Ilima 

Common sowthistle Sonchus oleraceus Pualele 

Jamaican feverplant Tribulus cistoides Nohu 

Coat buttons Tridax procumbens 

Golden crown-beard Verbesina encelioides 

Uhaloa Waltheria indica ‘Uhaloa 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

 

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

Appendix B. Compatibility Determinations and Appropriate Use 

Findings 

B.1 Introduction 

The compatibility determinations (CDs) developed during the CCP planning process evaluate uses 

projected to occur at the Keālia Pond NWR over the next 15 years. The evaluation of funds needed 

for management and implementation of each use also assumes implementation as described in 

Chapter 2. Chapter 7 of the CCP/EA also contains analysis of the impacts of public uses to wildlife 

and habitats. That portion of the document is intended to be incorporated through reference into this 

set of CDs. 

B.1.1 Uses Evaluated At This Time 

The following CDs are presented as draft in this draft CCP/EA for public review and comment. 

Table B-1. Summary of Compatibility Determinations. 

Refuge Use Page Compatible? Year Due for 

Reevaluation 

Wildlife Observation, Photography, and Interpretation B-5 Yes 2026 

Environmental Education B-11 Yes 2026 

Research, Scientific Collecting, and Surveys B-17 Yes 2021 

Kiawe Tree Harvesting B-27 Yes 2021 

B.1.2 Compatibility – Legal and Historical Context 

Compatibility is a tool refuge managers use to ensure that recreational and other uses do not interfere 

with wildlife conservation, the primary focus of refuges. Compatibility is not new to the Refuge 

System and dates back to 1918 as a concept. As policy, it has been used since 1962. The Refuge 

Recreation Act of 1962 directed the Secretary of the Interior to allow only those public uses of 

Refuge lands that were “compatible with the primary purposes for which the area was established.” 

Legally, Refuges outside of Alaska are closed to all public uses until officially opened. Regulations 

require that adequate funds be available for administration and protection of refuges before opening 

them to any public uses. However, wildlife-dependent recreational uses (hunting, fishing, wildlife 

observation and photography, environmental education (EE) and interpretation) are to receive 

enhanced consideration and cannot be rejected simply for lack of funding resources unless the refuge 

has made a concerted effort to seek out funds from all potential partners. Once found compatible, 

wildlife-dependent recreational uses are deemed the priority public uses at the refuge. If a proposed 

use is found not compatible, the refuge manager is legally precluded from approving it. Economic 

uses that are conducted by or authorized by the refuge also require CDs. 

Under compatibility policy, uses are defined as recreational, economic/commercial, or management 

use of a refuge by the public or a non-Refuge System entity. Uses generally providing an economic 

return (even if conducted for the purposes of habitat management) are also subject to CDs. The 

Service does not prepare CDs for uses when the Service does not have jurisdiction. For example, the 
Keālia Pond National Wildlife Refuge 

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B-2 Appendix B: Compatibility Determinations and Appropriate Use Findings 

Service may have limited jurisdiction over Refuge areas where property rights are vested by others; 

where legally binding agreements exist; or where there are treaty rights held by tribes. In addition, 

aircraft over-flights, emergency actions, some activities on navigable waters, and activities by other 

Federal agencies on “overlay Refuges” are exempt from the compatibility review process. 

New compatibility regulations were adopted by the Service in October 2000. The regulations require 

that a use must be compatible with both the Refuge System mission and the purpose(s) of the 

individual Refuge. This standard helps to ensure consistency in application across the Refuge 

System. The Administration Act also requires that CDs be in writing and that the public have an 

opportunity to comment on most use evaluations. 

The Refuge System mission emphasizes that the needs of fish, wildlife, and plants must be of 

primary consideration. The Administration Act defined a compatible use as one that “. . . in the sound 

professional judgment of the Director, will not materially interfere with or detract from the 

fulfillment of the mission of the System or the purposes of the Refuge.” Sound professional judgment 

is defined under the Administration Act as “. . . a finding, determination, or decision, that is 

consistent with principles of sound fish and wildlife management and administration, available 

science and resources . . .” Compatibility for wildlife-dependent uses may depend on the level or 

extent of a use. 

Court interpretations of the compatibility standard have found that compatibility is a biological 

standard and cannot be used to balance or weigh economic, political, or recreational interests against 

the primary purpose of the refuge (Defenders of Wildlife v. Andrus). 

The Service recognizes that CDs are complex. For this reason, refuge managers are required to 

consider “principles of sound fish and wildlife management” and “best available science” in making 

these determinations (House of Representatives Report 105-106). Evaluations of the existing uses on 

the Keālia Pond NWR are based on the professional judgment of Refuge and planning personnel 

including observations of Refuge uses and reviews of relevant scientific literature. 

B.1.3 Appropriate Use Findings 

The Appropriate Refuge Uses Policy outlines the process that the Service uses to determine when 

general public uses on refuges may be considered. Priority public uses previously defined as wildlifedependent uses (hunting, fishing, wildlife observation and photography and EE and interpretation) 

under the Administration Act are generally exempt from appropriate use review. Other exempt uses 

include situations where the Service does not have adequate jurisdiction to control the activity and 

refuge management activities. In essence, the Appropriate Use policy, 603 FW 1 (2006), provides 

refuge managers with a consistent procedure to first screen and then document decisions concerning 

a public use. When a use is determined to be appropriate, a refuge manager must then decide if the 

use is compatible before allowing it on a refuge. The policy also requires review of existing public 

uses. During the CCP process, the refuge manager evaluated all existing and proposed Refuge uses at 

Keālia Pond NWR using the guidelines and criteria as outlined in the appropriate use policy. 

Using this process, and as documented on the following pages, the Refuge Manager determined the 

following uses appropriate: “Research, Scientific Collecting, and Surveys” and “Kiawe Tree 

Harvesting.” 
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Appendix B: Compatibility Determinations and Appropriate Use Findings B-3 

Table B-2. Summary of Appropriate Use Findings. 

Refuge Use Page Appropriate?

Research, Scientific Collecting, and Surveys B-24 yes 

Kiawe Tree Harvesting B-33 yes 

B.1.4 References 

Compatibility regulations, adopted by the Service in October 2000: 

http://Refuges.fws.gov/policymakers/nwrpolicies.html 

Defenders of Wildlife v. Andrus (Ruby Lake Refuge I). 11 Envtl. Rptr. Case 2098 (D.D.C. 1978), 

p. 873. 

Fish and Wildlife Service. 2011. Keālia Pond National Wildlife Refuge: Draft Comprehensive 

Conservation Plan and Environmental Assessment. 

House of Representatives Report 105-106 

http://refuges.fws.gov/policyMakers/mandates/HR1420/part1.html 
Keālia Pond National Wildlife Refuge 

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B-4 Appendix B: Compatibility Determinations and Appropriate Use Findings 

B.2 Compatibility Determination for Wildlife Observation, Photography, 

and Interpretation

Refuge Name(s): Keālia Pond National Wildlife Refuge 

 

County and State: Maui County, Hawai‘i 

Establishing and Acquisition Authority(ies):

Keālia Pond NWR was established in 1992 under the authority of the: 

 Fish and Wildlife Coordination Act of 1956, as amended (16 U.S.C. 742a – 742j) 

 Endangered Species Act of 1973, as amended (16 U.S.C. 1531-1544) 

Refuge Purpose(s):

“...to conserve (A) fish and wildlife which, are listed as endangered or threatened species... or (B) 

Plants ...” 16 U.S.C. 1534, Endangered Species Act of 1973. 

National Wildlife Refuge System Mission: 

“The mission of the National Wildlife Refuge System is to administer a national network of lands 

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

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

generations of Americans” (Administration Act). 

Description of Use(s): 

The National Wildlife Refuge System Administration Act of 1966 (16 U.S.C. 668dd-668ee), as 

amended by the National Wildlife Refuge System Improvement Act of 1997 identifies wildlife 

observation and photography among wildlife-dependent public uses which, when compatible with 

the purpose(s) of the refuge, are priority public uses and receive special consideration in planning for 

and management of the Refuge System. 

Wildlife observation, photography and interpretation are non-consumptive, wildlife-dependent public 

uses with similar elements and so are considered together in this CD. Keālia Pond NWR is open to 

the public 5 days a week (closed on weekends), excluding Federal holidays. Public use activities 

take place at two areas on the Refuge, the Kanuimanu Ponds and the Keālia Coastal Boardwalk, with 

the goal of minimizing wildlife disturbance throughout the wetlands. The majority of use is selfguided. The Refuge has improved the public use facilities at these locations and the new visitor 

center will provide more formal learning opportunities and enhance their experience on the trails. 

Most of the wildlife observation, photography, and interpretation activities occur at the Kanuimanu 

Ponds. The 20 acres of constructed ponds are remnant of the previous aquaculture facility that was 

in full operation before the Refuge was established. The five ponds comprising this area are 

interconnected with levees that serve as the hiking trail. These earthen levees have been widened and 

compacted sufficiently to allow access for wheelchairs for most of the route. Wheelchairs, defined as 

a device specifically designed to be used indoors and outdoors by a person with a disability, are the 
Keālia Pond National Wildlife Refuge 

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Appendix B: Compatibility Determinations and Appropriate Use Findings B-5 

only motorized vehicles permitted on the trails. Pets are not allowed on the Refuge because of the 

openness of the area and close proximity to waterbirds. 

The Kanuimanu Ponds area is flat and open with no trees along the levees. Vegetation is limited to 

ground cover and grasses, mostly for waterbird use and access, and maintenance reasons. A visitor 

shelter is planned for future construction; this three-sided structure will be placed in the footprint of 

the previous office trailer next to the eight-stall parking lot. 

The Keālia Coastal Boardwalk is accessible from N. Kīhei Rd.; however, entry and exit into the 

parking area is only when traveling from Mā‘alaea (west side) to Kīhei (east side). This 

configuration allows safe sight distance when entering and exiting the lot due to the road’s alignment 

and adjacent curves. The boardwalk gates are opened at 6:00 a.m. and closed at 7:00 p.m. 

throughout the year (including weekends). 

The 2,200-foot long elevated boardwalk is for pedestrians to access the sensitive coastal habitat 

without impacting (trampling) the dunes for the purpose of wildlife observation and photography. 

Wildlife viewing (bird watching) activity is best during winter months when the coastal flats are 

flooded and with future capability of maintaining water on the flats, the opportunities would be yearround. This highly visible facility is well used for wildlife observation; however, the trail is also 

used by beach walkers since the three boardwalk ramps were intended to provide a loop trail. In 

general, all boardwalk users, whether intentionally observing wildlife or not, have the opportunity to 

learn about the wetlands and wildlife from the interpretive panels placed along the length. Since the 

opening of the boardwalk in September 2009, there has been an average of 15-20 people per day. 

The boardwalk is intended for pedestrian traffic only, excluding pets, bicycles, skateboards, and 

bikes. The boardwalk was constructed for access by persons with disabilities and is the best place on 

the Refuge for wheelchairs because of the smoother surface on the decking (compared with earthen 

levees). 

The new visitor center (HQ/VC) at Keālia Pond NWR is staffed by trained volunteers for direct 

contact with visitors that will enhance their wildlife observation and interpretation experiences. In 

addition, the exhibit hall has interpretive panels to introduce the visitors to the wetland and the 

resources for their outdoor observations. 

Availability of Resources:

Category and Itemization 

One-time 

$ 

Annual 

$/yr 

Administration and management: $0 $800 

Maintenance: $0 $5,400 

Monitoring costs: $0 $3,600 

Special equipment, facilities, or improvements: $0 $0 

Offsetting revenues: $0 $0 

The Refuge has sufficient budget and staff to manage this use. Wildlife observation, photography, 

and interpretation on the Refuge require minimal resources because the public is on their own; 

however, indirectly, resources in the form of facilities maintenance and wetland restoration to 

maintain viewing opportunities do exist. The HQ/VC is intended to prepare visitors with the basic 
Keālia Pond National Wildlife Refuge 

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B-6 Appendix B: Compatibility Determinations and Appropriate Use Findings 

ecology and biology of the Refuge to supplement their experience on the trails. 

Anticipated Impacts of the Use(s): 

There are different types of human-wildlife conflicts (direct or indirect; human-caused or wildlifecaused) that occur when people are in nature. Public use activities at Keālia Pond NWR are planned 

and designed to eliminate direct conflicts (e.g., harassment, direct mortality) and minimize indirect 

conflicts (disturbance as defined by a change in the wildlife’s behavior), as a rule. Wildlife 

observation and photography is identified as a priority use because of the importance of sharing what 

is being protected and the opportunities to increase visitors’ awareness, appreciation for, and 

stewardship towards the natural resources. A balance needs to be attained in order for human 

activities to coexist with waterbird needs. This can be accomplished by minimizing activities and 

designing public use facilities that allow birds to engage in their natural behaviors. 

Human activities on unconfined trails may result in direct effects on wildlife through harassment, a 

form of disturbance that can cause physiological effects or varying levels of behavioral modifications 

(Smith and Hunt 1995). Various studies have shown that the severity of the effects depends upon the 

distance to the disturbance and its duration, frequency, predictability, and visibility to wildlife 

(Knight and Cole 1991). The variables found to have the greatest influence on wildlife behavior are: 

a) the distance from the animal to the disturbance , b) duration of the disturbance, and c) the amount 

and kind of vegetative cover. In addition, the type of movement by people elicits different responses; 

for examples, birds show a greater flight response from a human moving quickly and unpredictably 

(erratic) than to humans moving slowly following a distinct path. Excessive human noises, 

especially with erratic behavior, are also a factor in bird disturbance by humans. 

Keālia Pond NWR has two areas where the public engages in wildlife observation and photography: 

the Kanuimanu Ponds and the Keālia Coastal Boardwalk. 

Short-term impacts: Keālia Pond NWR has been open to the public for approximately 17 years 

during which time the staff has observed and monitored public use activities and waterbird behavior 

to formalize general rules and conditions for public access onto the Kanuimanu Pond levees. Based 

on this history, the Refuge will continue offering wildlife observation and photography opportunities 

because the short-term impacts can be offset by minimizing or eliminating human disturbance. 

Activities are limited to pedestrian access only. Vehicles and bikes are not allowed on the levees or 

boardwalk and pets (even on leashes) are not permitted. The presence of people observing or 

photographing wildlife at Keālia Pond NWR has potential to cause short-term disturbances to 

wildlife. However, a majority of the visitors are in small groups (1-5) that create minimal 

disturbance of birds. Large tours or groups are typically birdwatchers that are goal-oriented and 

intent on minimal disturbance. Large non-wildlife-dependent groups are not the norm; however, if 

excessive disturbance is observed, the Refuge would mitigate through group education and 

interpretation. The staff will continue to monitor public use of the Refuge, identify when birds are 

most susceptible to human disturbance, and implement measures to eliminate and/or minimize the 

human activities for the benefit of endangered waterbirds. 

Long-term impacts: Short-term impacts can be minimized by managing human activities; 

however, these impacts can have cumulative effects on waterbirds. During nesting season, trails are 

closed to public access to eliminate disturbance to waterbirds incubating eggs and rearing young. In 

the past, this closure has occurred during ‘alae ke‘oke‘o nesting period (January-February); however, 
Keālia Pond National Wildlife Refuge 

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Appendix B: Compatibility Determinations and Appropriate Use Findings B-7 

this is not necessary every year, likely due to the location of their nests (in emergent vegetation in the 

main pond) hidden from view. In addition, during brood rearing, the young have the capability of 

swimming into the vegetation away from people. In contrast, closures are more typical during ae‘o 

nesting season (May-June) because of the location of their nests (on the ground, adjacent to water), 

low tolerance to disturbance, and the chicks’ limited ability to escape. In general, visitors’ responses 

to these closures appear to be acceptable, especially since the bird observations are still available 

from the parking area or areas adjacent to the boardwalk. 

Wildlife disturbances can also be minimized when planning the restoration of wetlands or facilities. 

The Kanuimanu Ponds is the primary area for public use; however, this was only by convenience: 

the ponds were pre-existing as aquaculture ponds before the Refuge was established. When the 

ponds were recently restored, one of the primary objectives was to enhance habitat for endangered 

waterbirds; however, the use was not expected to create prime nesting habitat more so than foraging 

habitat because the area was open to the public. Instead, the ponds were designed to attract a 

diversity of waterbirds throughout the year for wildlife observation and photography. The vegetation 

along the slope and in the ponds in addition to combining small ponds into larger ponds created 

habitat away from trails for waterbirds to seek shelter, if necessary. This type of planning is expected 

to minimize short- and long-term effects to waterbirds. 

Refuge staff will continue to monitor public use activities and evaluate potential disturbances in 

future planning and design of public use facilities. Future planning will also include methods to 

provide a high-quality experience to the public (e.g., bird observation or photo blinds). With the 

opening of a visitor center and the expected increase in public use, attention to this balance between 

waterbird use and public use will be essential to retain a quality wildlife observation and photography 

program. 

Cumulative impacts: The level and type of use from activities described in this CD is not expected 

to result in any significant cumulative impacts. 

Public Review and Comment: 

The period of public review began _________ and ended __________. 

Public review and comments were solicited in conjunction with release of the draft Keālia Pond 

NWR draft CCP/ EA (2011) in order to comply with the National Environmental Policy Act and 

Service policy. This CD was released as integral part of the CCP and received the same level of 

public review and comments as the CCP, in accordance with Service planning policy. 

Determination: (check one below) 

 Use is Not Compatible 

 ✓ Use is Compatible With Following Stipulations 

Stipulations Necessary to Ensure Compatibility: 

 Visitors are required to stay on trails and designated paths throughout the year; 

 Use is restricted to daylight hours only; and 

 Pets are not allowed. 
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B-8 Appendix B: Compatibility Determinations and Appropriate Use Findings 

 Regulations will be available to the public through a Refuge brochure and interpretive panels; 

 Directional, informational, and interpretive signs will be available and maintained to help 

keep visitors on the trails and help educate the public on minimizing wildlife and habitat 

disturbances; 

 Human use levels will be monitored; and 

 Temporary closure of trails will be performed during waterbird nesting season, if necessary, 

to eliminate disturbance. 

Justification: 

Wildlife observation, photography, and interpretation are three of the six wildlife-dependent 

recreational uses of the Refuge System identified in the Administration Act as legitimate and 

appropriate priority general public uses. The six uses — hunting, fishing, wildlife observation and 

photography, and EE and interpretation — are to receive enhanced consideration in planning and 

management over all other general public uses of the Refuge System. Wildlife observation, 

photography and interpretation receive enhanced consideration in the CCP process, and are 

considered priority public uses when determined compatible. Although these activities can result in 

disturbance to wildlife, these activities would occur on a small percentage of Refuge acres. There is a 

sufficient amount of undisturbed habitat available to Refuge wildlife for escape and cover, and 

wildlife populations will find sufficient food resources and resting places. The relatively limited 

number of individual plants and animals expected to be adversely affected will not cause wildlife 

populations to materially decline, the physiological condition and production of refuge species will 

not be impaired, their behavior and normal activity patterns will not be altered dramatically, and their 

overall welfare will not be negatively impacted. Thus, allowing wildlife observation, photography, 

and interpretation to occur under the stipulations described above will not materially detract or 

interfere with the purposes for which the Refuge was established or the refuge mission. Wildlife 

observation, photography, and interpretation programs complement the Refuge purpose, vision, and 

goals, and help fulfill the mission of the Refuge System. 

Mandatory Reevaluation Date: 

August 2026 Mandatory 15-year reevaluation date (for wildlife-dependent public uses) 

 Mandatory 10-year reevaluation date (for all uses other than wildlife-dependent public 

uses) 

NEPA Compliance for Refuge Use Decision: (check one below) 

 Categorical Exclusion without Environmental Action Statement 

 Categorical Exclusion and Environmental Action Statement 

 Environmental Assessment and Finding of No Significant Impact 

 Environmental Impact Statement and Record of Decision 
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Appendix B: Compatibility Determinations and Appropriate Use Findings B-9 

Refuge Determination:

 

Prepared by: 

Refuge Planner, 

Hawaiian and Pacific Islands NWRC 

 ___ 

 (Signature) (Date) 

Project Leader, 

Maui National Wildlife Refuge Complex 

Approval: 

 ___ 

 (Signature) (Date) 

Concurrence: 

Project Leader, 

Hawaiian and Pacific Islands NWRC 

 ___ 

 (Signature) (Date) 

Regional Chief, 

National Wildlife Refuge System: 

 ___ 

 (Signature) (Date) 

 
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B-10 Appendix B: Compatibility Determinations and Appropriate Use Findings 

B.3 Compatibility Determination for Environmental Education 

Refuge Name(s): Keālia Pond National Wildlife Refuge 

 

County and State: Maui County, Hawai‘i 

Establishing and Acquisition Authority(ies):

Keālia Pond NWR was established in 1992 under the authority of the: 

 Fish and Wildlife Coordination Act of 1956, as amended (16 U.S.C. 742a – 742j) 

 Endangered Species Act of 1973, as amended (16 U.S.C. 1531-1544) 

Refuge Purpose(s):

“...to conserve (A) fish and wildlife which, are listed as endangered or threatened species... or (B) 

Plants ...” 16 U.S.C. 1534, Endangered Species Act of 1973. 

National Wildlife Refuge System Mission: 

“The mission of the National Wildlife Refuge System is to administer a national network of lands 

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

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

generations of Americans” (Administration Act). 

Description of Use(s): 

The National Wildlife Refuge System Administration Act of 1966 (16 U.S.C. 668dd-668ee), as 

amended by the National Wildlife Refuge System Improvement Act of 1997 identifies environmental 

education and interpretation among wildlife-dependent public uses which, when compatible with the 

purpose(s) of the refuge, are priority public uses and receive special consideration in planning for and 

management of the National Wildlife Refuge System. 

Environmental education (EE) is a non-consumptive, wildlife-dependent public use Environmental 

education programs at Keālia Pond NWR are conducted by non-government organizations (Hawai‘i 

Nature Center, Maui Digital Bus) under a Special Use Permit. All outdoor classes are held at the 

Kanuimanu Ponds and are coordinated to not impact the Refuge’s management programs (e.g., 

monthly bird censuses, maintenance). Hawai‘i Nature Center’s 3rd grade wetland curriculum is held 

January-February each year. This time period is preferred because the ponds have water, vegetation, 

and high bird use for their observations and hands-on explorations. The Maui Digital Bus conducts 

their program throughout the year and is dependent on teachers’ inquiries. Both programs have been 

successful in reaching a high number (averages 1,500-2,000 students) and diversity of Maui’s school 

children, and engages them in activities emphasizing the value of wetlands, endangered species, and 

ecological concepts (food chains, waterbird adaptations, invertebrate life cycles) all of which include 

hands on activities. The Refuge’s role for these programs is to provide the site where a diversity of 

waterbird species are present and active learning is available in an outdoor setting. 
Keālia Pond National Wildlife Refuge 

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Appendix B: Compatibility Determinations and Appropriate Use Findings B-11 

Availability of Resources:

Category and Itemization 

One-time

$ 

Annual

$/yr 

Administration and management: $0 $1,000

Maintenance: $0 $900

Materials: $0 $1,000

Special equipment, facilities, or improvements: $0 $1,000

Offsetting revenues: $0 $

Minimal costs of EE will be covered by Refuge visitor services funding provided in the annual 

Refuge budget. 

Anticipated Impacts of the Use(s):

Short-term impacts: Under the current program, the number of school groups and students visiting 

the Refuge may vary from year to year but this variation is already considered in the guidelines and 

structure established for the program. The primary impacts come from temporary disturbance to 

individual animals (primarily birds) due to the presence and activity of the students as they are 

guided around the wetlands. The animals may flush, swim away, or seek cover and hide in 

vegetation. These impacts are mitigated by restricting the days, maximum number of students, and 

routes that EE activities take place. This allows the students to participate in the EE experience 

while causing temporary disturbance over the smallest area and to the fewest birds. 

This program has been in place for more than 12 years and has not had a noticeable impact on bird 

populations using the Refuge. 

Long-term impacts: The current, ongoing EE program covered by this CD will not cause any 

significant long-term impacts. The EE program is expected to increase with the development of a 

formal program designed to meet DOE requirements; however, a thorough evaluation of the impacts 

to existing resources and capability of the site to withstand additional groups will be reviewed in a 

Visitor Services Management Plan within 5 years. The recruitment of a Visitor Services Manager to 

oversee the public use facilities and activities, and a new visitor center will likely attract more 

teachers and other educators to the site. Alternative sites such as the Keālia Coastal Boardwalk will 

also be evaluated as a potential EE site, thereby relieving the Kanuimanu Ponds for other wildlifedependent activities. 

Cumulative impacts: This EE program has been conducted in the current manner for more than 12 

years and no cumulative impacts to wildlife resources on the Refuge have been observed or are 

anticipated. 

 
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B-12 Appendix B: Compatibility Determinations and Appropriate Use Findings 

Public Review and Comment:

The period of public review began _________ and ended __________. 

Public review and comments were solicited in conjunction with release of the draft CCP/EA (2011) 

in order to comply with the NEPA and Service policy. 

Determination: (check one below) 

 Use is Not Compatible 

 ✓ Use is Compatible with Following Stipulations 

Stipulations Necessary to Ensure Compatibility: 

User stipulations: 

 Groups are required to stay on trails and designated paths throughout the year. 

 Use is restricted to daylight hours only. 

 Groups are limited to a certain number of students and teachers. 

Administrative stipulations: 

 Specific regulations and allowances are outlined in the Special Use Permits. 

 Refuge-specific requirements are put in place to direct groups to staging areas and routes that 

do not impede normal refuge operations and are safe for students. 

 Use levels will be monitored 

 Temporary closure of trails will be performed during waterbird nesting season, if necessary, 

to eliminate disturbance. 

 Refuge staff periodically participates with the group to ensure compliance with Refuge’s 

conditions and accuracy of information is maintained. 

Justification: 

Environmental education is one of the six wildlife-dependent recreational uses of the Refuge System 

as stated in the Administration Act of 1997. The six uses — hunting, fishing, wildlife observation 

and photography, and EE and interpretation — are to receive enhanced consideration in planning and 

management over all other general public uses of the Refuge System. Environmental education 

receives enhanced consideration in the CCP process, and is considered a priority public use when 

determined compatible. By limiting the size of groups, providing structured activities, and providing 

closed areas for wildlife away from human disturbance, this program would limit disturbances to 

wildlife. There is a sufficient amount of undisturbed habitat available to Refuge wildlife for escape 

and cover, and wildlife populations will find sufficient food resources and resting places. The 

relatively limited number of individual plants and animals expected to be adversely affected will not 

cause wildlife populations to materially decline, the physiological condition and production of refuge 

species will not be impaired, their behavior and normal activity patterns will not be altered 

dramatically, and their overall welfare will not be negatively impacted. Thus, allowing EE to occur 

under the stipulations described above will not materially detract or interfere with the purposes for 

which the Refuge was established or the Refuge mission. Environmental education contributes to the 

mission of the Refuge System by providing wildlife-oriented educational benefits to visitors. 

Environmental education programs on Refuge lands are inherently valuable to the Service because 
Keālia Pond National Wildlife Refuge 

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Appendix B: Compatibility Determinations and Appropriate Use Findings B-13 

they will enhance the public’s knowledge of the Refuge and its resources, and expand the number of 

visitors who engage in the Refuge’s conservation mission. 

Mandatory Reevaluation Date: (provide month and year for “allowed” uses only) 

August 2026 Mandatory 15-year reevaluation date (for wildlife-dependent public uses) 

 Mandatory 10-year reevaluation date (for uses other than wildlife-dependent public uses) 

NEPA Compliance for Refuge Use Decision: (check one below) 

 Categorical Exclusion without Environmental Action Statement 

 Categorical Exclusion and Environmental Action Statement 

 Environmental Assessment and Finding of No Significant Impact 

 Environmental Impact Statement and Record of Decision
Keālia Pond National Wildlife Refuge 

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B-14 Appendix B: Compatibility Determinations and Appropriate Use Findings 

Refuge Determination:

 

Prepared by: 

Refuge Planner, 

Hawaiian and Pacific Islands NWRC 

 ___ 

 (Signature) (Date) 

Project Leader, 

Maui National Wildlife Refuge Complex 

Approval: 

 ___ 

 (Signature) (Date) 

Concurrence: 

Project Leader, 

Hawaiian and Pacific Islands NWRC 

 ___ 

 (Signature) (Date) 

Regional Chief, 

National Wildlife Refuge System: 

 ___ 

 (Signature) (Date) 

 
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Appendix B: Compatibility Determinations and Appropriate Use Findings B-15 

B.4 Compatibility Determination for Research, Scientific Collecting, 

 and Surveys 

CD Terminology: 

Research: Planned, organized, and systematic investigation of a scientific nature. 

Scientific collecting: Gathering of Refuge natural resources or cultural artifacts for scientific 

purposes. 

Surveys: Scientific inventory or monitoring. 

Refuge Name(s): Keālia Pond National Wildlife Refuge

 

County and State: Maui County, Hawai‘i

Establishing and Acquisition Authority(ies): 

Keālia Pond NWR was established in 1992 under the authority of the: 

 Fish and Wildlife Coordination Act of 1956, as amended (16 U.S.C. 742a – 742j) 

 Endangered Species Act of 1973, as amended (16 U.S.C. 1531-1544) 

Refuge Purpose(s): 

“...to conserve (A) fish and wildlife which, are listed as endangered or threatened species... or (B) 

Plants ...” 16 U.S.C. 1534, Endangered Species Act of 1973. 

National Wildlife Refuge System Mission: 

“The mission of the National Wildlife Refuge System is to administer a national network of lands 

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

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

generations of Americans” (Administration Act). 

Description of Use(s): 

We receive periodic requests from non-Service entities (e.g., universities, State agencies, other 

Federal agencies, non-governmental organizations) to conduct research, scientific collecting, and 

surveys on Refuge lands. These project requests can involve a wide range of natural and cultural 

resources as well as public use management issues, including basic absence/presence surveys, 

collection of new species for identification, habitat use and life-history requirements for specific 

species/species groups, practical methods for habitat restoration, extent and severity of environmental 

contaminants, techniques to control or eradicate pest species, effects of climate change on 

environmental conditions and associated habitat/wildlife response, identification and analyses of 

paleontological specimens, modeling wildlife populations, and assessing response of habitat/wildlife 

to disturbance from public uses. Projects may be species-specific, Refuge-specific, or evaluate the 

relative contribution of the Refuge lands to larger landscapes (e.g., eco-region, region, flyway, 

national, international) issues and trends. 
Keālia Pond National Wildlife Refuge 

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B-16 Appendix B: Compatibility Determinations and Appropriate Use Findings 

The Service’s research and management and Appropriate Refuge Uses (603 FW1.10D(4)) policies 

indicate priority for scientific investigatory studies that contribute to the enhancement, protection, 

use, preservation, and management of native wildlife populations and their habitat as well as their 

natural diversity. Projects that contribute to refuge-specific needs for resource and/or wilderness 

management goals and objectives, where applicable, would be given a higher priority over other 

requests. 

Availability of Resources: 

Refuge staff responsibilities for projects by non-Service entities will primarily be limited to the 

following: review of proposals, prepare Special Use Permits (SUP) and other compliance documents 

(e.g., Section 7 of the ESA, Section 106 of the National Historic Preservation Act), and monitor 

project implementation to ensure that impacts and conflicts remain within acceptable levels 

(compatibility) over time. Additional administrative support, logistical and operational support may 

also be provided depending on each specific request. Estimated costs for one-time (e.g., prepare 

SUP) and annually recurring tasks by Refuge staff and other Service employees will be determined 

for each project. Sufficient funding in the general operating budget of the Refuge must be available 

to cover expenses for these projects. The terms and conditions for funding and staff support 

necessary to administer each project on the Refuge will be clearly stated in the SUP. 

The Refuge has the following staffing and funding to administratively support and monitor research 

that is currently taking place on Refuge lands (see table below). Any substantial increase in the 

number of projects would create a need for additional resources to oversee the administration and 

monitoring of the investigators and their projects. Any substantial additional costs above those 

itemized below may result in finding a project not compatible unless expenses are offset by the 

investigator(s), sponsoring agency, or organization. 

Category and Itemization One-time $ Annual $/yr 

Administration and management $0 $2,000

Maintenance $0 $0

Monitoring $0 $3,900

Special equipment, facilities, or improvement $0 $0

Offsetting revenues $0 $0

Itemized costs in the table above are current estimates calculated using 7 percent of the base cost for a GS-11 

Refuge Biologist and 3 percent of the base cost for a GS-12 Refuge Manager. 

Anticipated Impacts of the Use: 

Use of the Refuge(s) to conduct research, scientific collecting, and surveys will generally provide 

information that would benefit fish, wildlife, plants, and their habitats. Scientific findings gained 

through these projects provide important information regarding life-history needs of species and 

species groups as well as identify or refine management actions to achieve resource management 

objectives in Refuge management plans (especially CCPs). Reducing uncertainty regarding wildlife 

and habitat responses to management actions in order to achieve desired outcomes reflected in 

resource management objectives is essential for adaptive management in accordance with 522 DM 1. 

If project methods impact or conflict with Refuge-specific resources, priority wildlife-dependent 

public uses, other high-priority research, and Refuge habitat and wildlife management programs, then 

it must be clearly demonstrated that the scientific findings will contribute to resource management 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

 

Appendix B: Compatibility Determinations and Appropriate Use Findings B-17 

and that the project cannot be conducted off-Refuge for the project to be compatible. The 

investigator(s) must identify methods/strategies in advance required to eliminate or minimize the 

potential impact(s) and conflict(s). If unacceptable impacts cannot be avoided, then the project will 

not be compatible. 

Impacts would be project- and site-specific, where they will vary depending upon nature and scope 

of the field work. Data collection techniques will generally have minimal animal mortality or 

disturbance, habitat destruction, no introduction of contaminants, or no introduction of non-native 

species. In contrast, projects involving the collection of biotic samples (plants or animals) or 

requiring intensive ground-based data or sample collection will have short-term impacts. To reduce 

impacts, the minimum number of samples (e.g., water, soils, vegetative litter, plants, 

macroinvertebrates, and vertebrates) will be collected for identification and/or experimentation and 

statistical analysis. Where possible, researchers would coordinate and share collections to reduce 

sampling needed for multiple projects. Investigator(s) obtaining required State and Federal collecting 

permits will also ensure minimal impacts to fish, wildlife, plants, and their habitats. If, after 

incorporating the above strategies, the project results in long-term or cumulative effects, it will not be 

deemed compatible. A Section 7 consultation under the ESA will be required for activities that may 

affect a federally listed species and/or critical habitat. Only projects that have no effect or will result 

in not likely to adversely affect determinations will be considered compatible. 

Spread of pest plants and/or pathogens is possible from ground disturbance and/or transportation of 

project equipment and personnel, but it will be minimized or eliminated by requiring proper cleaning 

of investigator equipment and clothing as well as quarantine methods, where necessary. If after all 

practical measures are taken, an unacceptable spread of pest species is anticipated to occur, then the 

project will be found not compatible without a restoration or mitigation plan. Localized and 

temporary effects may occur from vegetation trampling, collecting of soil and plant samples, or 

trapping and handling of wildlife. Impacts may also occur from infrastructure necessary to support a 

project (e.g., permanent transects or plot markers, exclosure devices, monitoring equipment, solar 

panels to power unattended monitoring equipment). Some level of disturbance is expected with these 

projects, especially if investigator(s) enter areas closed to the public and collect samples or handle 

wildlife. However, wildlife disturbance (including altered behavior) will usually be localized and 

temporary in nature. Where long-term or cumulative unacceptable effects cannot be avoided, the 

project will not be found compatible. 

At least 6 months before initiation of field work (unless an exception is made by prior approval of the 

Refuge Manager), project investigator(s) must submit a detailed proposal. Project proposals will be 

reviewed by Refuge staff and others, as needed, to assess the potential impacts (short-term, longterm, and cumulative) relative to benefits of the investigation to Refuge management issues and 

understanding of natural systems. This assessment will form the primary basis for allowing or 

denying a specific project. Projects that result in unacceptable Refuge impacts will not be found 

compatible. If allowed and found compatible after approval, all projects also will be assessed during 

implementation to ensure impacts and conflicts remain within acceptable levels. If the proposal is 

approved, the Refuge Manager will issue a SUP(s) with required stipulations (terms and conditions) 

of the project to avoid and/or minimize potential impacts to Refuge resources as well as conflicts 

with other public-use activities and Refuge field management operations. After approval, projects 

also are monitored during implementation to ensure impacts and conflicts remain within acceptable 

levels based upon documented stipulations. Projects that are not covered by the CCP will require 

additional NEPA documentation. 
Keālia Pond National Wildlife Refuge 

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B-18 Appendix B: Compatibility Determinations and Appropriate Use Findings 

Public Review and Comment: 

The period of public review began _________ and ended __________. 

Public review and comments were solicited in conjunction with release of the draft CCP/EA (2011) 

in order to comply with the NEPA and Service policy. 

Determination: (check one below) 

 The use is not compatible. 

 ✓ The use is compatible with the following stipulations. 

Stipulations Necessary to Ensure Compatibility: 

Each project will require an SUP. Annual or other short-term SUPs are preferred; however, some 

permits will be a longer period, if needed, to allow completion of the project. All SUPs will have a 

definite termination date. Permit renewals will be subject to Refuge Manager review and approval 

based on timely submission of and content in progress reports, compliance with SUP stipulations, 

and required permits. Other stipulations and provisions would include the following:

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

and applicable. 

 Investigators must possess appropriate and comply with conditions of State and Federal 

permits for their projects. 

 If unacceptable impacts to natural resources or conflicts arise or are documented by the 

Refuge staff, then the Refuge Manager can suspend, modify conditions of, or terminate an 

on-going project already permitted by SUP(s) on a Refuge. 

 Progress reports are required at least annually for multiple-year projects. 

 Final reports are due 1 year after completion of the project unless negotiated otherwise with 

the Refuge Manager. 

 Continuation of existing projects will require approval by the Refuge Manager. 

 The Refuge staff will be given the opportunity to review draft manuscript(s) from the project 

before being submitted to a scientific journal(s) for consideration of publication. 

 The Refuge staff will be provided with copies (including, but not limited to: reprints, videos, 

and CDs) of all publications resulting from a Refuge project. 

 The Refuge staff will be provided with copies of raw data (electronic database format) at the 

conclusion of the project. 

 Upon completion of the project or annually, all equipment and markers unless required for 

long-term projects must be removed and sites must restored to the Refuge Manager’s 

satisfaction. Conditions for clean-up and removal of equipment and physical markers will be 

stipulated in the SUP(s). 

 All samples collected on Refuge lands are the property of the Service even while in the 

possession of the investigator(s). Any future work with previously collected samples not 

clearly identified in the project proposal will require submission of a subsequent proposal for 

review and approval. In addition, a new SUP will be required for additional project work. For 

samples or specimens to be stored at other facilities (e.g., museums), a memorandum of 

understanding will be necessary. 
Keālia Pond National Wildlife Refuge 

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Appendix B: Compatibility Determinations and Appropriate Use Findings B-19 

 Sampling equipment as well as investigator(s) clothing and vehicles (e.g., ATV, boats) will 

be thoroughly cleaned (free of dirt and plant material) before being allowed for use on 

Refuge lands and/or waters to prevent the introduction and/or spread of pests. 

 The Service, specific Refuge unit, names of Refuge staff and other Service personnel who 

supported or contributed to the project will be appropriately cited and acknowledged in all 

written and oral presentations resulting from projects on Refuge lands. 

 At any time, Refuge staff may accompany investigator(s) in the field. 

 Investigator(s) and support staff will follow all Refuge-specific regulations for access and 

travel on the Refuge. 

Justification: 

Research, scientific collecting, and surveys on Refuge lands are inherently valuable to the Service 

because they will expand scientific information available for resource management decisions. In 

addition, only projects that directly or indirectly contribute to the enhancement, protection, use, 

preservation, and management of Refuge wildlife populations and their habitats generally will be 

authorized on Refuge lands. In many cases, if it were not for the Refuge staff providing access to 

Refuge lands and waters along with some support, the research project would likely not occur and 

less scientific information would be available to the Service to aid in managing and conserving 

resources. By allowing the use to occur under the stipulations described above, it is anticipated that 

wildlife species that could be disturbed during the use would find sufficient food resources and 

resting places so their abundance and use will not be measurably lessened on the Refuge. 

Additionally, it is anticipated that monitoring, as needed, will prevent unacceptable or irreversible 

impacts to fish, wildlife, plants, and their habitats. The combination of stipulations identified above 

and conditions included in any SUP(s) will ensure that proposed projects contribute to the 

enhancement, protection, conservation, and management of native wildlife populations and their 

habitats on the Refuge. As a result, these projects will not materially interfere with or detract from 

fulfilling Refuge purpose(s); contributing to the mission of the Service and Refuge System; and 

maintaining the biological integrity, diversity, and environmental health of the Refuge. 

Mandatory Re-evaluation Date: (provide month and year for “allowed” uses only) 

 Mandatory 15-year re-evaluation date (wildlife-dependent public uses) 

August 2021 Mandatory 10-year re-evaluation date (uses other than wildlife-dependent public uses) 

NEPA Compliance for Refuge Use Decision: (check one below)

 Categorical Exclusion and Environmental Action Statement 

 

 Environmental Assessment and Finding of No Significant Impact 

 Environmental Impact Statement and Record of Decision 

 
Keālia Pond National Wildlife Refuge 

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B-20 Appendix B: Compatibility Determinations and Appropriate Use Findings 

Refuge Determination:

 

Prepared by: 

Refuge Planner, 

Hawaiian and Pacific Islands NWRC 

 ___ 

 (Signature) (Date) 

Project Leader, 

Maui National Wildlife Refuge Complex 

Approval: 

 ___ 

 (Signature) (Date) 

Concurrence: 

Project Leader, 

Hawaiian and Pacific Islands NWRC 

 ___ 

 (Signature) (Date) 

Regional Chief, 

National Wildlife Refuge System: 

 ___ 

 (Signature) (Date) 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

 

Appendix B: Compatibility Determinations and Appropriate Use Findings B-21 

FINDING OF APPROPRIATENESS OF A REFUGE USE

Refuge Name:   Keālia Pond National Wildlife Refuge  

Use:   Research, Scientific Collecting, and Surveys

This form is not required for wildlife‐dependent recreational uses; take regulated by the State, or uses already described in a

refuge CCP or step‐down management plan approved after October 9, 1997.

Where we do not have jurisdiction over the use (“no” to (a)), there is no need to evaluate it further as we cannot control the

use. Uses that are illegal, inconsistent with existing policy, or unsafe (“no” to (b), (c), or (d)) may not be found appropriate. If

the answer is “no” to any of the other questions above, we will generally not allow the use.

If indicated, the refuge manager has consulted with State fish and wildlife agencies. Yes _✔__ No __  

When the refuge manager finds the use appropriate based on sound professional judgment, the refuge manager must justify

the use in writing on an attached sheet and obtain the refuge supervisor’s concurrence. Based on an overall assessment of

these factors, my summary conclusion is that the proposed use is:  

Not Appropriate_____ Appropriate_✔  

Refuge Manager:________________________________________ Date:_____________________  

If found to be Not Appropriate, the refuge supervisor does not need to sign concurrence if the use is a new use. If an existing

use is found Not Appropriate outside the CCP process, the refuge supervisor must sign concurrence. If found to be

Appropriate, the refuge supervisor must sign concurrence.  

Refuge Supervisor:_______________________________________ Date:_____________________  

Decision Criteria: YES NO 

(a) Do we have jurisdiction over the use? ✔ 

(b) Does the use comply with applicable laws and regulations (Federal, State, tribal, and local)? ✔ 

(c) Is the use consistent with applicable Executive orders and Department and Service policies? ✔ 

(d) Is the use consistent with public safety? ✔ 

(e) Is the use consistent with goals and objectives in an approved management plan or other 

document? ✔ 

(f) Has an earlier documented analysis not denied the use or is this the first time the use has 

been proposed? ✔ 

(g) Is the use manageable within available budget and staff? ✔ 

(h) Will this be manageable in the future within existing resources? ✔ 

(i) Does the use contribute to the public’s understanding and appreciation of the refuge’s natural 

or cultural resources, or is the use beneficial to the refuge’s natural or cultural resources? ✔ 

(j) Can the use be accommodated without impairing existing wildlife-dependent recreational 

uses or reducing the potential to provide quality (see section 1.6D, 603 FW 1, for description), 

compatible, wildlife-dependent recreation into the future? 

✔ 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

B-22 Appendix B: Compatibility Determinations and Appropriate Use Findings 

FWS Form 3-2319 

A compatibility determination is required before the use may be allowed. 02/06 

Attachment 1: Appropriate Uses Justification 

Date: May 5, 2011 

Refuge: Keālia Pond National Wildlife Refuge (Refuge) 

Project: Research, Scientific Collecting, and Surveys 

Summary: The Refuge receives requests to conduct scientific research on Refuge lands and waters. 

Research applicants must submit a proposal that would outline: (1) objectives of the study; 

(2) justification for the study; (3) detailed methodology and schedule; (4) potential impacts on 

Refuge wildlife and/or habitat, including disturbance (short-term and long-term), injury, or mortality; 

(5) personnel required; (6) costs to Refuge, if any; and (7) end products (i.e., reports, publications). 

Research proposals would be reviewed by Refuge staff, Regional Office Branch of Refuge Biology, 

and others as appropriate prior to the Refuge issuing a SUP. Projects will not be open-ended, and, at 

a minimum, will be reviewed annually. 

 

For each of the findings listed on FWS Form 3-2319, a justification has been provided below: 

a. Do we have jurisdiction over the use? 

Some or all of the proposed activities would take place within Refuge boundaries. The Refuge has 

jurisdiction over those research projects that are sited within Refuge boundaries. 

b. Does the use comply with applicable laws and regulations (Federal, State, tribal, and local)? 

Proposed research activities should comply with all applicable laws and regulations. Any restrictions 

or qualifications that are required to comply with law and regulations would be specified in the SUP. 

The State of Hawai‘i DLNR was invited on two occasions to participate on core planning teams, but 

declined due to insufficient staffing. However, as this Appropriate Use Justification does not propose 

a significant deviation from the status quo, and no comments on this topic were received from the 

State during the comment period, we believe additional coordination is not necessary. 

c. Is the use consistent with applicable Executive orders and Department and Service policies? 

Through the review of individual projects, the Refuge would ensure that they are consistent with 

applicable policies, especially Research on Service Lands Policy (803 FW 1). 

d. Is the use consistent with public safety? 

Through individual project review, the Refuge will ensure that each project is consistent with public 

safety. If necessary, stipulations to ensure public safety will be included in the project’s SUP. 

 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

 

Appendix B: Compatibility Determinations and Appropriate Use Findings B-23 

e. Is the use consistent with goals and objectives in an approved management plan or other 

document? 

Research activities are approved in instances where they can provide meaningful data that may 

contribute to Refuge management and public appreciation of natural resources. 

f. Has an earlier documented analysis not denied the use or is this the first time the use has 

been proposed? 

Earlier documented analysis has approved the use and touted the benefits of research, scientific 

collecting, and surveys on national wildlife refuges. 

g. Is the use manageable within available budget and staff? 

The Refuge receives <10 requests per year for this activity, and it is manageable with available 

budget and staff. 

h. Will this be manageable in the future within existing resources? 

The proposed activity at current levels would be manageable in the future with the existing resources. 

i. Does the use contribute to the public’s understanding and appreciation of the Refuge’s 

natural or cultural resources, or is the use beneficial to the Refuge’s natural or cultural 

resources? 

The proposed use is beneficial to the Refuge’s natural and cultural resources because the types of 

research projects approved are those that have the distinct likelihood to help achieve Refuge purposes 

by providing information useful for the management of trust resources and may contribute to the 

public’s understanding and appreciation of natural and/or cultural resources. 

j. Can the use be accommodated without impairing existing wildlife-dependent recreational 

uses or reducing the potential to provide quality (see section 1.6D, 603 FW 1, for description), 

compatible, wildlife-dependent recreation into the future? 

The Refuge will ensure that the research activities will not impair existing or future wildlifedependent recreational use of the Refuge during individual project review, prior to issuing a SUP for 

the project. 

 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

B-24 Appendix B: Compatibility Determinations and Appropriate Use Findings 

B.5 Compatibility Determination for Kiawe Tree Harvesting

Refuge Name(s): Keālia Pond National Wildlife Refuge 

 

County and State: Maui County, Hawai‘i 

Establishing and Acquisition Authority(ies):

Keālia Pond NWR was established in 1992 under the authority of the: 

 Fish and Wildlife Coordination Act of 1956, as amended (16 U.S.C. 742a – 742j) 

 Endangered Species Act of 1973, as amended (16 U.S.C. 1531-1544) 

Refuge Purpose(s):

“...to conserve (A) fish and wildlife which, are listed as endangered or threatened species... or (B) 

Plants ...” 16 U.S.C. 1534, Endangered Species Act of 1973. 

National Wildlife Refuge System Mission: 

“The mission of the National Wildlife Refuge System is to administer a national network of lands 

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

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

generations of Americans” (Administration Act). 

Description of Use(s): 

The forested area at Keālia Pond NWR is predominantly kiawe trees (mesquite) – a non-native 

species which is advantageous as a buffer around the wetland but is host to cattle egret colonies, 

particularly along the north edge of the wetlands. The Refuge has occasionally (0-1 annually) 

received requests to cut kiawe for firewood and fence posts to accomplish specific community events 

(Kīhei Canoe Club, Halau Maui Nui o Kama) and projects (The Nature Conservancy, Kamehameha 

Schools, East Maui Watershed Partnership). 

Kiawe removal areas are predefined and delineated by Refuge staff. A typical project would cover 4 

acres with the removal of 20 trees to be used for 40 fence posts. Unused woody debris may be 

mulched. Stumps are treated with glyphosate to keep them from re-sprouting. All kiawe debris 

material that has not been finely mulched, including excess branches, must be removed at the user’s 

expense and taken off-Refuge to the green waste site. 

Although the wood was not sold, it represents a commodity with market value, therefore, by 

definition removing the wood is a commercial use. By regulation (50 CFR 29.1, we can only allow 

commercial uses to occur if the use contributes to achieving Refuge purposes. The activity of 

removing kiawe is for the benefit of the wetland and waterbirds by reducing predation and 

disturbances by non-native cattle egrets. Kiawe removal at targeted locations is also necessary for native 

forest restoration. 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

 

Appendix B: Compatibility Determinations and Appropriate Use Findings B-25 

In the past, a couple of groups known to manage natural areas were given the opportunity to take 

wood when they assisted Refuge staff as a volunteer. This volunteer effort was only allowed in a 

predefined area that the Refuge was already clearing to open up the perimeter of a permanent pond. 

In preparation for future inquiries, the Refuge is including the evaluation of Appropriate Use and 

preparation of the Compatibility Determination within the Keālia Pond NWR CCP/EA. 

Availability of Resources:

Category and Itemization 

One-time 

$ 

Annual 

$/yr 

Administration and management: $0 $800

Maintenance: $0 $0

Monitoring costs: $0 $0

Special equipment, facilities, or improvements: $0 $0

Offsetting revenues: $0 $0

The Refuge has sufficient budget and staff to manage this use. 

Anticipated Impacts of the Use(s): 

Short-term impacts: 

Removal of cattle egrets’ roost and colonies provides only short-term impacts because other kiawe 

trees are available; however, the Refuge targets areas adjacent to wetlands to minimize disturbance 

and predation on endangered Hawaiian waterbirds. Allowing clubs to harvest and remove kiawe 

reduces the Refuge cost to pay to have the wood hauled to a green waste facility. 

Long-term impacts: 

We will see a net reduction of kiawe over time. The long-term impacts would be a minor decrease in 

the number of cattle egrets present on the Refuge, thereby reducing egret predation on waterbird 

chicks. Removal of kiawe is necessary for native planting reforestation efforts. 

Cumulative impacts: The level and type of use from activities described in this CD is not expected 

to result in any significant cumulative impacts as the amount of wood removed is negligible 

compared to the total forested area. 

. 

Public Review and Comment: 

The period of public review began BBBBBBBBBDQGHQGHGBBBBBBBBBB. 

Public review and comments were solicited in conjunction with release of the draft CCP/EA (2011) 

in order to comply with the NEPA and Service policy. 

Determination: (check one below) 

 Use is Not Compatible 

 ✓ Use is Compatible With Following Stipulations 
Keālia Pond National Wildlife Refuge 

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B-26 Appendix B: Compatibility Determinations and Appropriate Use Findings 

Stipulations Necessary to Ensure Compatibility: 

User stipulations: 

 Submit formal written request with documentation on the purposes for kiawe wood; 

 Use is restricted to daylight hours when Refuge staff are present; 

 Pets are not allowed; 

 User is limited to areas predefined and delineated by Refuge staff; 

 All kiawe debris material, including excess branches, must be removed at the User’s expense 

and taken off-Refuge to the green waste site; 

 Equipment is limited to a chain saw (user supplied) which is in safe operating condition and 

all personal protective equipment must be worn (hard hat with safety shield, chaps, gloves, 

etc.); 

 Refuge staff will inspect site and kiawe load being removed upon user departure; 

 Access to site off entrance road or parking area is on foot only; and 

 User will arrive with vehicle, equipment, and clothing free of any soil, seeds, or invertebrates 

to prevent introduction of pest species to the Refuge. 

Administrative stipulations: 

 Regulations will be provided in writing and verbally reviewed with the user before initiating 

work; 

 Permit will be specific to the individual (primary point of contact that must be present) and 

will cover no more than 3 workers for a set period of time; 

 Kiawe removal will only be in areas where the Refuge is performing restoration, typically 

adjacent to wetlands; 

 Kiawe harvesting is limited to the months from September-November; 

 The Refuge has the right to disapprove a request if the intent is for sale purposes; and 

 The Refuge has the right to terminate an already approved User/Permitee if: rules and 

regulations are not followed; safety is impaired due to carelessness; waterbird impacts are 

greater than expected; safety of Refuge staff, visitors, or volunteers are in jeopardy; 

Justification: 

Kiawe trees are a pest plants on the Refuge that provide breeding and roosting habitat for the nonnative cattle egret. Cattle egrets have been known prey on chicks of all endangered waterbird species 

occurring on the Refuge. Kiawe overshadows native plants and deep taproots use all available water. 

Dense kiawe thickets have replaced native plants in the coastal dry forest at Keālia Pond NWR. 

Harvesting of kiawe trees will achieve an indirect predator control strategy for cattle egrets identified 

under Objective 1.1 and enhance shrub land habitat as identified in Objective 2.1 of the CCP. This 

management action will remove an existing cattle egret rookery adjacent to Kanuimanu ponds and 

may be used to control future rookeries in other stands of kiawe trees on the Refuge. Partnering with 

non-governmental, non-profit, conservation-oriented organizations to remove the trees and process 

the wood for use on other conservation projects supports environmental sustainability and promotes 

the recovery of endangered Hawaiian waterbirds. By allowing the use to occur under the stipulations 

described above, it is anticipated that adverse impacts to wildlife species can be avoided by timing 

the harvesting activities when birds are not using the area. Additionally, it is anticipated that 

monitoring will prevent unacceptable or irreversible impacts to fish, wildlife, plants, and their 

habitats. As a result, not only does this kiawe tree harvesting activity not materially interfere with or 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

 

Appendix B: Compatibility Determinations and Appropriate Use Findings B-27 

detract from fulfilling Refuge purposes, it contributes to achieving Refuge purposes by removing a 

pest plant species from the habitat and reducing the habitat for another pest species.

Mandatory Reevaluation Date: (provide month and year for “allowed” uses only) 

_________Mandatory 15-year reevaluation date (for wildlife-dependent public uses) 

 May 2021Mandatory 10-year reevaluation date (for all uses other than wildlife-dependent public 

uses) 

NEPA Compliance for Refuge Use Decision: (check one below) 

 _ Categorical Exclusion without Environmental Action Statement 

_ Categorical Exclusion and Environmental Action Statement 

  Environmental Assessment and Finding of No Significant Impact 

 _ Environmental Impact Statement and Record of Decision 
Keālia Pond National Wildlife Refuge 

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B-28 Appendix B: Compatibility Determinations and Appropriate Use Findings 

Refuge Determination:

 

Prepared by: 

Refuge Planner, 

Hawaiian and Pacific Islands NWRC 

 ___ 

 (Signature) (Date) 

Project Leader, 

Maui National Wildlife Refuge Complex 

Approval: 

 ___ 

 (Signature) (Date) 

Concurrence: 

Project Leader, 

Hawaiian and Pacific Islands NWRC 

 ___ 

 (Signature) (Date) 

Regional Chief, 

National Wildlife Refuge System: 

 ___ 

 (Signature) (Date) 

 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

 

Appendix B: Compatibility Determinations and Appropriate Use Findings B-29 

FINDING OF APPROPRIATENESS OF A REFUGE USE

Refuge Name:   Keālia Pond  National Wildlife Refuge  

Use:   Kiawe Tree Harvesting

This form is not required for wildlife‐dependent recreational uses; take regulated by the State, or uses already described in a

refuge CCP or step‐down management plan approved after October 9, 1997.

Where we do not have jurisdiction over the use (“no” to (a)), there is no need to evaluate it further as we cannot control the

use. Uses that are illegal, inconsistent with existing policy, or unsafe (“no” to (b), (c), or (d)) may not be found appropriate. If

the answer is “no” to any of the other questions above, we will generally not allow the use.

If indicated, the refuge manager has consulted with State fish and wildlife agencies. Yes _✔__ No __  

When the refuge manager finds the use appropriate based on sound professional judgment, the refuge manager must justify

the use in writing on an attached sheet and obtain the refuge supervisor’s concurrence. Based on an overall assessment of

these factors, my summary conclusion is that the proposed use is:  

Not Appropriate_____ Appropriate_✔  

Refuge Manager:________________________________________ Date:_____________________  

If found to be Not Appropriate, the refuge supervisor does not need to sign concurrence if the use is a new use. If an existing

use is found Not Appropriate outside the CCP process, the refuge supervisor must sign concurrence. If found to be

Appropriate, the refuge supervisor must sign concurrence.  

Refuge Supervisor:_______________________________________ Date:_____________________  

Decision Criteria: YES NO 

(a) Do we have jurisdiction over the use? ✔ 

(b) Does the use comply with applicable laws and regulations (Federal, State, tribal, and local)? ✔ 

(c) Is the use consistent with applicable Executive orders and Department and Service policies? ✔ 

(d) Is the use consistent with public safety? ✔ 

(e) Is the use consistent with goals and objectives in an approved management plan or other 

document? ✔ 

(f) Has an earlier documented analysis not denied the use or is this the first time the use has 

been proposed? ✔ 

(g) Is the use manageable within available budget and staff? ✔ 

(h) Will this be manageable in the future within existing resources? ✔ 

(i) Does the use contribute to the public’s understanding and appreciation of the refuge’s natural 

or cultural resources, or is the use beneficial to the refuge’s natural or cultural resources? ✔ 

(j) Can the use be accommodated without impairing existing wildlife-dependent recreational 

uses or reducing the potential to provide quality (see section 1.6D, 603 FW 1, for description), 

compatible, wildlife-dependent recreation into the future? 

✔ 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

B-30 Appendix B: Compatibility Determinations and Appropriate Use Findings 

FWS Form 3-2319 

A compatibility determination is required before the use may be allowed. 02/06 

Attachment 1: Appropriate Uses Justification 

Date: May 5, 2011 

Refuge: Keālia Pond National Wildlife Refuge (Refuge) 

Project: Kiawe tree harvesting 

Summary: The Refuge has received requests to cut kiawe for firewood and fence posts for specific 

community events (Kīhei Canoe Club, Halau Maui Nui o Kama), projects (The Nature Conservancy, 

Kamehameha Schools, East Maui Watershed Partnership). 

Kiawe are non-native species that serve as a buffer protecting wetlands from upper land use activities; an 

area where surface water flows from streams filter suspended sediment and slows down water before 

entering the main pond; perching structure for pueo; and cattle egret roost and colonies. Providing habitat 

for cattle egrets is the primary negative impact of kiawe along the wetland boundaries and a management 

need that the Refuge has been addressing within the last 2-3 years. 

One effort to control cattle egrets at the Refuge is to remove trees where birds are roosting and nesting. 

These areas are easy to identify because of the large colonies that form. Chemical and mechanical 

treatment has shown to be an effective method to impact a large number of birds, especially areas 

adjacent to wetlands where endangered waterbird nesting occurs. Accessibility to these areas is difficult 

due to the density and moist soil conditions; therefore, the Refuge attempts to remove trees using 

chainsaws. 

Another management objective strategy includes the removal of kiawe to allow for protection of native 

plant species. Reforestation to a natural native lowland forest will require the removal of non-native 

kiawe, 

If natural resource groups are in need of kiawe for fence posts or Hawaiian cultural practices then it may 

be possible to permit these specific users to harvest kiawe so long as the areas are in coordination with the 

Refuge’s management objectives and the removal benefits endangered waterbirds (minimize predation 

and disturbances by cattle egrets). 

 

For each of the findings listed on FWS Form 3-2319, a justification has been provided below: 

a. Do we have jurisdiction over the use? 

All of the proposed activity would take place within Refuge boundaries. The Refuge only has 

jurisdiction over those projects that are sited within Refuge boundaries. 

b. Does the use comply with applicable laws and regulations (Federal, State, tribal, and local)? 

Proposed kiawe tree harvesting activities should comply with all applicable laws and regulations. 

Any restrictions or qualifications that are required to comply with law and regulations would be 

specified in the SUP. 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

 

Appendix B: Compatibility Determinations and Appropriate Use Findings B-31 

c. Is the use consistent with applicable Executive orders and Department and Service policies? 

Yes. It follows the waterbird recovery plan by minimizing predation by cattle egrets by eliminating 

roost sites. 

d. Is the use consistent with public safety? 

Through individual project review, the Refuge will ensure that each project is consistent with public 

safety. Stipulations to ensure public safety will be included in the project’s SUP. 

e. Is the use consistent with goals and objectives in an approved management plan or other 

document? 

Kiawe removal will only be permitted if the activity is in conjunction or in assistance with the 

Refuge’s habitat management plan and protection of endangered Hawaiian waterbirds and restoration 

of a native plant community. This activity is intended as a management tool.

f. Has an earlier documented analysis not denied the use or is this the first time the use has 

been proposed? 

This is the first time the use has been proposed for formal review. 

g. Is the use manageable within available budget and staff? 

The Refuge receives 0-1 request per year for this activity, and it is manageable with available budget 

and staff. 

h. Will this be manageable in the future within existing resources? 

The proposed activity at current levels would be manageable in the future with the existing resources. 

i. Does the use contribute to the public’s understanding and appreciation of the Refuge’s 

natural or cultural resources, or is the use beneficial to the Refuge’s natural or cultural 

resources? 

The proposed use is beneficial to the Refuge’s natural and cultural resources and may contribute to 

the public’s understanding and appreciation of natural and/or cultural resources. 

j. Can the use be accommodated without impairing existing wildlife-dependent recreational 

uses or reducing the potential to provide quality (see section 1.6D, 603 FW 1, for description), 

compatible, wildlife-dependent recreation into the future? 

The Refuge will ensure that the research activities will not impair existing or future wildlifedependent recreational use of the Refuge during individual project review, prior to issuing a SUP for 

the project. 

 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

B-32 Appendix B: Compatibility Determinations and Appropriate Use Findings 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix C: Plan Implementation and Costs C-1 

Appendix C. Plan Implementation and Costs 

C.1 Administration 

Keālia Pond NWR is administered as part of the Maui National Wildlife Refuge Complex 

(Complex). The Complex also includes the Kakahai‘a NWR, comprised of two wetland units along 

the south coast of Moloka‘i. The Complex is currently in the process of establishing Molokini Islet 

as a Refuge unit of the Keālia Pond NWR that will also have oversight from the Complex office. 

The Complex headquarters is located at Keālia Pond NWR with the majority of the facilities and 

maintenance containers. A new Complex headquarters/visitor center is in construction with a 

projected opening in August 2011. This facility and associated staff would also serve the Kakahai‘a 

NWR and Molokini Islet Refuge unit. 

C.2 Staffing 

All staff positions share responsibilities and duties for two refuges, in addition to Molokini Islet Unit, 

once established; e.g., no staff is assigned or performs duties only on specific refuges within the 

Complex. Due to projected Complexwide workload, priorities, logistics, and supervisory 

considerations, this arrangement is expected to continue. However, when more personnel are added 

to the Complex (e.g., a Maintenance Worker or Equipment Operator), staff may be assigned more 

specific duties on individual refuges. 

The Service’s National Staffing Model generated eight positions for the Maui NWR Complex with 

seven stationed at Keālia Pond NWR. The existing, core-funded staff is four, so four additional 

positions are justified. The additional staffing would provide increased capacity to conduct 

biological inventory and monitoring, and research; increased visitor opportunities; environmental 

education and interpretation of Refuge resources; collaborative efforts with other Federal, State, and 

County agencies in addition to non-government organizations; improved maintenance facilities; and 

increase invasive species control efforts for the benefit of endangered waterbirds. 

The Complex’s new visitor center was unplanned when staffing models were finalized; therefore, the 

need for staff to operate and maintain the new building was not included in planning. Increased 

staffing with specific responsibilities in the development of the visitor, volunteer, and education 

programs, and maintaining the new facility is necessary to provide quality customer service and 

ensure safe conditions for visitors. 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

C-2 Appendix C: Plan Implementation and Costs 

Current and Necessary Permanent Full-time Staffing for Maui NWR Complex, including 

Kakahai‘a NWR on Molokai (Current staff positions are highlighted) 

Staff Position Salary Rating

Identified in 

National Staffing 

Model

HQ/VC

Project Leader GS-12 

Deputy Project Leader GS-9/11 

Wildlife Biologist GS-11 

Biological Science Technician GS-5/7

Visitor Services Manager GS-7/9/11  

Refuge Ranger GS-5/7 

Administrative Support Assistant GS-7 

Maintenance Worker (Habitat & Facilities) WG-8 

Maintenance Worker (Facilities) WG-7/8 

Equipment Operator WG-6/7 

Law Enforcement Officer GS-7/9 

C.4 Refuge Funding and Budget Requests

Successful implementation of the CCP relies on our ability to secure funding, personnel, 

infrastructure, and other resources to accomplish the actions identified. Full implementation of the 

actions and strategies in this CCP will incur costs including staffing, construction projects, and 

individual resource program expansions. In addition to annual budget allocations, funding can be 

received through special funding sources and programs geared toward specific resource issues/needs. 

Examples include grants or project specific funding for endangered species, pest species control, 

wetlands, coastal habitats, climate change, and Service initiatives (Youth in the Great Outdoors, 

Connecting People with Nature). 

Currently there are two sources of funding that will enable the Keālia Pond NWR to carry out its 

plans under the CCP, including additional staff; these sources includes the Refuge Operating Needs 

System (RONS) and Service Asset Maintenance Management System (SAMMS) for 

repair/renovation of existing facilities. The RONS and SAMMS systems will be updated with 

new/additional projects that are approved under this CCP. 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix C: Plan Implementation and Costs C-3 

Project Dates Cost Estimate 

Develop, plan, and implement visitor services, education, and 

volunteer programs ( Visitor Services Manager) 

 

$ 117,598 

Control invasive cattle egret predation on endangered waterbirds 

$ 130,000 

Restore emergent wetlands and mudflats on the southeast side of 

Kanuimanu Ponds 

 

$ 171,573 

Implement waterbird recovery actions (Biological Technician) $ 77,615 

Erect predator fence to protect endangered Hawaiian waterbirds $ 750,000 

Restore natural groundwater-fed ponds in forested habitat $ 115,000 

Restore east mudflats for endangered waterbirds $ 38,578 

Install pump and water distribution system at Mā‘alaea Flats $ 75,000 

Restore east mudflats for endangered Hawaiian waterbirds $ 39,073 

Implement Visitor Services, Education, and Volunteer Programs 

(Refuge Ranger) 

 

$ 77,615 

Provide Visitor, Resource, and Facility Protection (Law Enforcement 

Officer) 

 $ 150,000 

Construct well, pump, and water distribution system on north edge of 

marsh 

 $75,000 

Construct water control structure and pumping capability at Keālia 

Pond outlet 

 $ 350,000 

Construct long-term water source to restore 60 acres of coastal 

wetlands at Mā‘alaea Flats 

 $ 75,000

Construct new shop/maintenance facility $ 600,000 

- Does not include facilities (e.g., public roads, parking areas, boardwalks, etc.) that will be identified in the 

Visitor Services Plan 

C. 5 Stepdown Plans 

The CCP is one of several plans necessary for Refuge management. The CCP provides guidance in 

the form of goals, objectives, and strategies for several Refuge program areas but may lack some of 

the specifics needed for implementation. Stepdown management plans will be developed for 

individual program areas within approximately 5 years after CCP completion. Stepdown plans, 

where feasible, will be prepared to cover all Refuges in the Complex. All stepdown plans require 

appropriate NEPA compliance and implementation may require additional permits. Stepdown plans 

for the Refuge follow in the table below. Project-specific plans, with appropriate NEPA compliance, 

may be prepared outside of these stepdown plans. 

 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

C-4 Appendix C: Plan Implementation and Costs 

Stepdown Management Plan Status

Completed Date 

 Habitat Management Plan 2011 (CCP meets requirements for HMP) 

 Integrated Pest Management Plan 2011 (Prepared concurrently with CCP, Appendix E) 

 Fire Management Plan 2004 (Appendix G) 

 Occupational Safety and Health Plan 2009 

Scheduled

 Inventory and Monitoring Plan Initiated by 2012 

 Visitor Services Plan Initiated by 2012 

 Environmental Education Plan Initiated by 2013 

 Land Protection Plan Initiated by 2012 

Studies Identified in CCP Strategies

 Topographical mapping of Mā‘alaea Flat 2012 

 Comprehensive Water Resources Assessment 2012 

 ‘Ōka‘i ‘aiea (Blackburn Sphinx Moth): population, 

mapping, and habitat 

2012 

 Geomorphological Assessment 2012-2014 

 Climate Change Monitoring Plan Initiated in 2011 

 Biological and Botanical Assessment of Molokini 

Islet 

2013-2015 

 ‘Ua‘u kani population model for Molokini Islet to 

identify carrying capacity and dispersal to Maui 

2013-2015 

 Breeding phenology of ‘ou on Molokini Islet 2013-2015 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix D: Wilderness Review D-1 

Appendix D: Wilderness Review for Keālia Pond NWR 

General Information on Wilderness Reviews 

Wilderness review is the process used to determine whether or not to recommend lands or waters in 

the Refuge System to Congress for designation as wilderness. Planning policy for the Refuge System 

(602 FW 3) mandates conducting wilderness reviews every 15 years through the CCP process. 

The wilderness review process has three phases: inventory, study, and recommendation. After first 

identifying lands and waters that meet the minimum criteria for wilderness, the resulting wilderness 

study areas (WSA) are further evaluated to determine if they merit recommendation from the Service 

to the Secretary of the Interior for inclusion in the National Wilderness Preservation System 

(NWPS). Areas recommended for designation are managed to maintain wilderness character in 

accordance with management goals, objectives, and strategies outlined in the final CCP until 

Congress makes a decision or the CCP is amended to modify or remove the wilderness proposal. A 

brief discussion of wilderness inventory, study, and recommendation follows. 

Wilderness Inventory 

The wilderness inventory consists of identifying areas that minimally meet the requirements for 

wilderness as defined in the Wilderness Act of 1964 (Wilderness Act). Wilderness is defined as an 

area which: 

 Has at least 5,000 ac of land or is of sufficient size as to make practicable its preservation 

and use in an unimpaired condition, or be capable of restoration to wilderness character 

through appropriate management at the time of review, or be a roadless island; 

 Generally appears to have been affected primarily by the forces of nature, with the imprint 

of man’s work substantially unnoticeable; 

 Has outstanding opportunities for solitude or a primitive and unconfined type of recreation; 

and 

 May also contain ecological, geological, or other features of scientific, educational, scenic, 

or historic value. These features and values, though desirable, are not necessary for an area 

to qualify as a wilderness. 

Wilderness Study 

During the study phase, lands and waters qualifying for wilderness as a result of the inventory are 

studied to analyze values (ecological, recreational, cultural, spiritual), resources (wildlife, water, 

vegetation, minerals, soils), and uses (habitat management, public use) within the area. The findings 

of the study help determine whether to recommend the area for designation as wilderness. 

Wilderness Recommendation 

Once a wilderness study determines that a WSA meets the requirements for inclusion in the NWPS, a 

wilderness study report that presents the results of the wilderness review, accompanied by a 

Legislative Environmental Impact Statement (LEIS), is prepared. The wilderness study report and 

LEIS that support wilderness designation are then transmitted through the Secretary of the Interior to 

the President of the United States, and ultimately to the Congress for approval. 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

D-2 Appendix D: Wilderness Review 

The following section summarizes the inventory phase of the wilderness review for Keālia Pond 

NWR. 

Wilderness Inventory 

The wilderness inventory is a broad look at the planning area to identify WSAs. These WSAs are 

roadless areas within refuge boundaries, including submerged lands and their associated water 

column, that meet the minimum criteria for wilderness identified in Sect. 2. (c) of the Wilderness 

Act. A WSA must meet the minimum size criteria (or be a roadless island), appear natural, and 

provide outstanding opportunities for solitude or primitive recreation. Other supplemental values are 

evaluated, but not required. 

Evaluation of Size Criteria for Roadless Areas, Roadless Islands, and Submergent Lands and 

Associated Water Column 

Identification of roadless areas, roadless islands, and submerged lands and associated water column, 

required gathering land status maps, land use and road inventory data, satellite imagery, aerial 

photographs, and personal observations of areas within refuge boundaries. “Roadless” refers to the 

absence of improved roads suitable and maintained for public travel by means of motorized vehicles 

primarily intended for highway use. 

 

Inventory units meet the size criteria for a WSA if any one of the following standards applies: 

 An area with over 5,000 contiguous ac. State and private lands are not included in making 

this acreage determination. 

 A roadless island of any size. A roadless island is defined as an area surrounded by 

permanent waters or that is markedly distinguished from the surrounding lands by 

topographical or ecological features. 

 An area of less than 5,000 contiguous Federal acres that is of sufficient size as to make 

practicable its preservation and use in an unimpaired condition, and of a size suitable for 

wilderness management. 

 An area of less than 5,000 contiguous Federal acres that is contiguous with a designated 

wilderness, recommended wilderness, or area under wilderness review by another Federal 

wilderness managing agency such as the Forest Service, National Park Service, or Bureau of 

Land Management. 

Keālia Pond NWR, is a highly modified 691-acre parcel of land located on the island of Maui and 

does not meet the size criteria. It is also bounded and bisected by State-owned and Refuge-owned 

roadways maintained for travel by passenger vehicles. 

Evaluation of the Naturalness Criteria 

A WSA must meet the naturalness criteria. Section 2.(c) of the Wilderness Act defines wilderness as 

an area that “...generally appears to have been affected primarily by the forces of nature with the 

imprint of man’s work substantially unnoticeable.” The area must appear natural to the average 

visitor rather than “pristine.” The presence of ecologically accurate, historical landscape conditions is 

not required. An area may include some manmade features and human impacts provided they are 

substantially unnoticeable in the unit as a whole. Human-caused hazards, such as the presence of 

unexploded ordnance from military activity, and the physical impacts of refuge management 

facilities and activities are also considered in the evaluation of the naturalness criteria. An area may 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix D: Wilderness Review D-3 

not be considered unnatural in appearance solely on the basis of “sights and sounds” of human 

impacts and activities outside the boundary of the unit. The cumulative effects of these factors were 

considered in the evaluation of naturalness for each wilderness inventory unit. 

In the wilderness inventory, specific manmade features and other human impacts need to be 

identified that affect the overall apparent naturalness of the tract. The following factors were primary 

considerations in evaluating the naturalness of the Refuge: 

 Administrative and storage containers, greenhouse; 

 Well pumps, earthen dikes, exposed water lines, water control structures; and 

 Gates, parking lots, and roadways. 

 

Keālia Pond NWR is bounded and bisected by State-owned and refuge-owned roadways maintained 

for travel by passenger vehicles. This inventory unit contains numerous earthen dikes, ditches, 

roadways, buildings, and water control structures and does not meet the naturalness criteria. 

Evaluation of Outstanding Opportunities for Solitude or Primitive and Unconfined Recreation 

In addition to meeting the size and naturalness criteria, a WSA must provide outstanding 

opportunities for solitude or primitive recreation. The area does not have to possess outstanding 

opportunities for both solitude and primitive and unconfined recreation, and does not need to have 

outstanding opportunities on every acre. Further, an area does not have to be open to public use and 

access to qualify under these criteria. Congress has designated a number of wilderness areas in the 

NWPS that are closed to public access to protect ecological resource values. 

Opportunities for solitude refers to the ability of a visitor to be alone and secluded from other visitors 

in the area. Primitive and unconfined recreation means nonmotorized, dispersed outdoor recreation 

activities that do not require developed facilities or mechanical transport. These primitive recreation 

activities may provide opportunities to experience challenge and risk, self-reliance, and adventure. 

These two opportunity “elements” are not well defined by the Wilderness Act but in most cases can 

be expected to occur together. However, an outstanding opportunity for solitude may be present in an 

area offering only limited primitive recreation potential. Conversely, an area may be so attractive for 

recreation use that experiencing solitude is not an option. 

 

These inventory units do not offer opportunities for solitude or primitive and unconfined recreation. 

Daily management activities occur including road maintenance, mowing and disking of fields, and 

manipulation of water control structures. Recreational and educational activities are only conducted 

in group settings, and only allowed as staff-guided activities. 

Evaluation of Supplemental Values

Supplemental values are defined by the Wilderness Act as “ecological, geological, or other features 

of scientific, educational, scenic, or historic value.” Based upon the findings of the required 

components for WSA designation, supplemental values were not evaluated. 

Findings 

Keālia Pond NWR does not meet the minimum criteria for consideration as WSA (see Table D.1). 

 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

D-4 Appendix D: Wilderness Review 

Table D.1 Wilderness Inventory Summary

Wilderness Inventory Summary 

Keālia Pond NWR (691 acres) 

Required Components

(1) Has at least 5,000 ac of land or is of sufficient size 

to make practicable its preservation and use in an 

unconfined condition, or is a roadless island. 

No. Does not contain 5,000 acres, is not a roadless 

island, and is not practicable to manage as a wilderness. 

(2) Generally appears to have been affected primarily 

by the forces of nature, with the imprint of man’s work 

substantially unnoticeable. 

No. Landscape is highly modified and actively managed. 

(3a) Has outstanding opportunities for solitude. No. Refuge is actively and regularly managed. 

(3b) Has outstanding opportunities for a primitive and 

unconfined type of recreation. 

No. Recreation is highly regulated and requires staff 

presence. 

Other Components

(4) Contains ecological, geological or other features of 

scientific, educational, scenic, or historic value. 

Not evaluated. 

Summary

Parcel qualifies as a wilderness study area (meets 

criteria 1, 2 & 3a or 3b). 

No. 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix E: Integrated Pest Management Program E-1 

Appendix E: Integrated Pest Management Program, 

Keālia Pond NWR 

1.0 Background 

Integrated Pest Management (IPM) is an interdisciplinary approach utilizing methods to prevent, 

eliminate, contain, and/or control pest species in concert with other management activities on Refuge 

lands and waters to achieve wildlife and habitat management goals and objectives. The IPM is also a 

scientifically based, adaptive management process where available scientific information and best 

professional judgment of the Refuge staff as well as other resource experts would be used to identify 

and implement appropriate management strategies that can be modified and/or changed over time to 

ensure effective, site-specific management of pest species to achieve desired outcomes. In 

accordance with 43 CFR 46.145, adaptive management would be particularly relevant where longterm impacts may be uncertain and future monitoring would be needed to make adjustments in 

subsequent implementation decisions. After a tolerable pest population (threshold) is determined 

considering achievement of Refuge resource objectives and the ecology of pest species, one or more 

methods, or combinations thereof, are selected that are feasible, efficacious, and most protective of 

nontarget resources, including native species (fish, wildlife, and plants), and Service personnel, 

Service authorized agents, volunteers, and the public. Staff time and available funding will be 

considered when determining feasibility/practicality of various treatments. 

Our IPM techniques to address pests are presented as CCP strategies prescriptions (see Section 2.0 of 

this CCP) in an adaptive management context to achieve Refuge resource objectives. In order to 

satisfy requirements for IPM planning as identified in the Director’s Memo (dated September 9, 

2004) entitled Integrated Pest Management Plans and Pesticide Use Proposals: Updates, Guidance, 

and an Online Database, the following elements of an IPM program have been incorporated into this 

CCP: 

 Habitat and/or wildlife objectives that identify pest species and appropriate thresholds to indicate 

the need for and successful implementation of IPM techniques; and 

 Monitoring before and/or after treatment to assess progress toward achieving objectives including 

pest thresholds. 

Where pesticides would be necessary to address pests, this Appendix provides a structured procedure 

to evaluate potential effects of proposed uses involving ground-based applications to Refuge 

biological resources and environmental quality in accordance with effects analyses presented in 

Chapter 7.0 (Effects Analysis) of this CCP. Only pesticide uses that likely would cause minor, 

temporary, or localized effects to Refuge biological resources and environmental quality with 

appropriate best management practices (BMPs), where necessary, would be allowed for use on the 

Refuge. 

This Appendix does not describe the more detailed process to evaluate potential effects associated 

with aerial applications of pesticides. Moreover, it does not address effects of mosquito control with 

pesticides (larvicides, pupacides, or adulticides) based upon identified human health threats and 

presence of disease-carrying mosquitoes in sufficient numbers from monitoring conducted on a 

Refuge. However, the basic framework to assess potential effects to Refuge biological resources and 

environmental quality from aerial application of pesticides or use of insecticides for mosquito 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

E-2 Appendix E: Integrated Pest Management Program 

management would be similar to the process described in this Appendix for ground-based treatments 

of other pesticides. 

2.0 Pest Management Laws and Policies 

In accordance with 517 DM and 569 FW 1(Integrated Pest Management), plant, invertebrate, and 

vertebrate pests on units of the National Wildlife Refuge System can be controlled to assure balanced 

wildlife and fish populations in support of refuge-specific wildlife and habitat management 

objectives. Pest control on Federal (Refuge) lands and waters also is authorized under the following 

legal mandates: 

 National Wildlife Refuge System Administration Act of 1966, as amended (16 USC 668dd668ee); 

 Plant Protection Act of 2000 (7 USC 7701 et seq.); 

 Noxious Weed Control and Eradication Act of 2004 (7 USC 7781-7786, Subtitle E); 

 Federal Insecticide, Fungicide, and Rodenticide Act of 1996 (7 USC 136-136y); 

 National Invasive Species Act of 1996 (16 USC 4701); 

 Nonindigenous Aquatic Nuisance Prevention and Control Act of 1990 (16 USC 4701); 

 Food Quality Protection Act of 1996 (7 USC 136); 

 Executive Order 13148, Section 601(a); 

 Executive Order 13112; and 

 Animal Damage Control Act of 1931 (7 USC 426-426c, 46 Stat. 1468). 

Pests are defined as “...living organisms that may interfere with the site-specific purposes, 

operations, or management objectives or that jeopardize human health or safety” from Department 

policy 517 DM 1 (Integrated Pest Management Policy). Similarly, 569 FW 1 defines pests as 

“...invasive plants and introduced or native organisms that may interfere with achieving our 

management goals and objectives on or off our lands, or that jeopardize human health or safety.” 

517 DM 1 also defines an invasive species as “a species that is nonnative to the ecosystem under 

consideration and whose introduction causes or is likely to cause economic or environmental harm or 

harm to human health.” Throughout the remainder of this CCP, the terms pest and invasive species 

are used interchangeably because both can prevent/impede achievement of Refuge wildlife and 

habitat objectives and/or degrade environmental quality. 

In general, control of pests (vertebrate or invertebrate) on the Refuge would conserve and protect the 

nation’s fish, wildlife, and plant resources as well as maintain environmental quality. From 

569 FW 1, animal or plant species, which are considered pests, may be managed if the following 

criteria are met: 

 Threat to human health and well-being or private property, the acceptable level of damage by the 

pest has been exceeded, or State or local government has designated the pest as noxious; 

 Detrimental to resource objectives as specified in a Refuge resource management plan (e.g., 

comprehensive conservation plan, habitat management plan), if available; and 

 Control would not conflict with attainment of resource objectives or the purposes for which the 

Refuge was established. 

The specific justifications for pest management activities on the Refuge are the following: 

 Protect human health and well-being; 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix E: Integrated Pest Management Program E-3 

 Prevent substantial damage to important to Refuge resources; 

 Protect newly introduced or re-establish native species; 

 Control nonnative (exotic) species in order to support existence for populations of native species; 

 Prevent damage to private property; and 

 Provide the public with quality, compatible wildlife-dependent recreational opportunities. 

In accordance with Service policy 620 FW 1 (Habitat Management Plans), there are additional 

management directives regarding invasive species found on the Refuge: 

 “We are prohibited by Executive Order, law, and policy from authorizing, funding, or carrying 

out actions that are likely to cause or promote the introduction or spread of invasive species in the 

United States or elsewhere.” 

 “Manage invasive species to improve or stabilize biotic communities to minimize unacceptable 

change to ecosystem structure and function and prevent new and expanded infestations of 

invasive species. Conduct Refuge habitat management activities to prevent, control, or eradicate 

invasive species...” 

Animal species damaging/destroying Federal property and/or detrimental to the management 

program of a Refuge may be controlled as described in 50 CFR 31.14 (Official Animal Control 

Operations). 

Trespass and feral animals also may be controlled on Refuge lands. Based upon 50 CFR 28.43 

(Destruction of Dogs and Cats), dogs and cats running at large on a national wildlife refuge and 

observed in the act of killing, injuring, harassing or molesting humans or wildlife may be disposed of 

in the interest of public safety and protection of the wildlife. 

Feral animals should be disposed by the most humane method(s) available and in accordance with 

relevant Service directives (including Executive Order 11643). Disposed wildlife specimens may be 

donated or loaned to public institutions. Donation or loans of resident wildlife species will only be 

made after securing State approval (50 CFR 30.11 [Donation and Loan of Wildlife Specimens]). 

Surplus wildlife specimens may be sold alive or butchered, dressed and processed subject to Federal 

and State laws and regulations (50 CFR 30.12 [Sale of Wildlife Specimens]). 

3.0 Strategies 

To fully embrace IPM as identified in 569 FW 1, the following strategies, where applicable, would 

be carefully considered on the Refuge for each pest species: 

Prevention. This would be the most effective and least expensive long-term management option 

for pests. It encompasses methods to prevent new introductions or the spread of the established 

pests to un-infested areas. It requires identifying potential routes of invasion to reduce the 

likelihood of infestation. Hazard Analysis and Critical Control Points (HACCP) planning can be 

used determine if current management activities on a Refuge may introduce and/or spread 

invasive species in order to identify appropriate BMPs for prevention. 

Prevention may include source reduction, using pathogen-free or weed-free seeds or fill; 

exclusion methods (e.g., barriers) and/or sanitation methods (e.g., wash stations) to prevent reintroductions by various mechanisms including vehicles and personnel. Because invasive species 
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are frequently the first to establish newly disturbed sites, prevention would require a reporting 

mechanism for early detection of new pest occurrences with quick response to eliminate any new 

satellite pest populations. Prevention would require consideration of the scale and scope of land 

management activities that may promote pest establishment within un-infested areas or promote 

reproduction and spread of existing populations. Along with preventing initial introduction, 

prevention would involve halting the spread of existing infestations to new sites (Mullin et al. 

2000). The primary reason of prevention would be to keep pest-free lands or waters from 

becoming infested. Executive Order 11312 emphasizes the priority for prevention with respect to 

managing pests. 

The following would be methods to prevent the introduction and/or spread of pests on Refuge 

lands: 

 Before beginning ground-disturbing activities (e.g., disking, scraping), inventory and 

prioritize pest infestations in project operating areas and along access routes. Refuge 

staff would identify pest species on site or within reasonably expected potential invasion 

vicinity. Where possible, Refuge staff would begin project activities in un-infested areas 

before working in pest-infested areas. 

 Refuge staff would locate and use pest-free project staging areas. They would avoid or 

minimize travel through pest-infested areas, or restrict to those periods when spread of 

seed or propagules of invasive plants would be least likely. 

 Refuge staff would determine the need for, and when appropriate, identify sanitation sites 

where equipment can be cleaned of pests. Where possible, Refuge staff would clean 

equipment before entering lands at on-Refuge approved cleaning site(s). This practice 

does not pertain to vehicles traveling frequently in and out of the project area that will 

remain on roadways. Seeds and plant parts of pest plants would need to be collected, 

where practical. Refuge staff would remove mud, dirt, and plant parts from project 

equipment before moving it into a project area. 

 Refuge staff would clean all equipment, before leaving the project site, if operating in 

areas infested with pests. Refuge staff would determine the need for, and when 

appropriate, identify sanitation sites where equipment can be cleaned. 

 Refuge staffs, their authorized agents, and Refuge volunteers would, where possible, 

inspect, remove, and properly dispose of seed and parts of invasive plants found on their 

clothing and equipment. Proper disposal means bagging the seeds and plant parts and 

then properly discarding of them (e.g., incinerating). 

 Refuge staff would evaluate options, including closure, to restrict the traffic on sites with 

on-going restoration of desired vegetation. Refuge staff would revegetate disturbed soil 

(except travel ways on surfaced projects) to optimize plant establishment for each 

specific site. Revegetation may include topsoil replacement, planting, seeding, 

fertilization, liming, and weed-free mulching as necessary. Refuge staff would use native 

material, where appropriate and feasible. Refuge staff would use certified weed-free or 

weed-seed-free hay or straw where certified materials are reasonably available. 

 Refuge staff would provide information, training and appropriate pest identification 

materials to Refuge staffs, permit holders, and recreational visitors. Refuge staff would 

educate them about pest identification, biology, impacts, and effective prevention 

measures. 

 Refuge staff would inspect borrow material for invasive plants prior to use and transport 

onto and/or within Refuge lands. 
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 Refuge staff would consider invasive plants in planning for road maintenance activities. 

 Refuge staff would restrict off road travel to designated routes. 

The following would be methods to prevent the introduction and/or spread of pests into Refuge 

waters: 

 Refuge staff would inspect boats (including air boats), trailers, and other boating 

equipment and, where possible, remove any visible plants, animals, or mud before 

leaving any waters or boat launching facilities. Where possible, staff would drain water 

from motor, live well, bilge, and transom wells while on land before leaving the site. 

If possible, Refuge staff would wash and dry boats, downriggers, anchors, nets, floors of boats, 

propellers, axles, trailers, and other boating equipment to kill pests not visible at the boat launch. 

These prevention methods to minimize/eliminate the introduction and/or spread of pests were 

taken verbatim or slightly modified from Appendix E of US Forest Service (2005). 

 Mechanical/Physical Methods. These methods would remove and destroy, disrupt the growth 

of, or interfere with the reproduction of pest species. For plants species, these treatments can be 

accomplished by hand, hand tool (manual), power tools, or heavy equipment and include pulling, 

grubbing, digging, tilling/disking, cutting, swathing, grinding, sheering, girdling, mowing, and 

mulching of the pest plants. 

For animal species, Service employees or their authorized agents could use mechanical/physical 

methods (including trapping) to control pests as a refuge management activity. Based upon 

50 CFR 31.2, trapping can be used on a refuge to reduce surplus wildlife populations for a 

“balanced conservation program” in accordance with Federal or State laws and regulations. In 

some cases, trapped animals would be relocated to off-refuge sites with prior approval from the 

State. 

Each of these tools would be efficacious to some degree and applicable to specific situations. In 

general, mechanical controls can effectively control annual and biennial pest plants. However, to 

control perennial plants, the root system has to be destroyed or it would resprout and continue to 

grow and develop. Mechanical controls are typically not capable of destroying a perennial plants 

root system. Although some mechanical tools (e.g., disking, plowing) may damage root systems, 

they may stimulate regrowth producing a denser plant population that may aid in the spread 

depending upon the target species. In addition, steep terrain and soil conditions would be major 

factors that can limit the use of many mechanical control methods. 

Some mechanical control methods (e.g., mowing), which would be used in combination with 

herbicides, can be a very effective technique to control perennial species. For example, mowing 

perennial plants followed sequentially by treating the plant regrowth with a systemic herbicide 

often would improve the efficacy of the herbicide compared to herbicide treatment only. 

 Cultural Methods. These methods would involve manipulating habitat to increase pest 

mortality by reducing its suitability to the pest. Cultural methods would include water-level 

manipulation, , prescribed burning (facilitate revegetation, increase herbicide efficacy, and 

remove litter to assist in emergence of desirable species), planting or seeding desirable species to 
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shade or out-compete invasive plants, applying fertilizer to enhance desirable vegetation, 

irrigation, and other habitat alterations. 

 Biological Control Agents. Classical biological control would involve the deliberate 

introduction and management of natural enemies (parasites, predators, grazing animals or 

pathogens) to reduce pest populations. Many of the most ecologically or economically damaging 

pest species in the United States originated in foreign countries. These newly introduced pests, 

which are free from natural enemies found in their country or region of origin, may have a 

competitive advantage over cultivated and native species. This competitive advantage often 

allows introduced species to flourish, and they may cause widespread economic damage to crops 

or out compete and displace native vegetation. Once the introduced pest species population 

reaches a certain level, traditional methods of pest management may be cost prohibitive or 

impractical. Biological controls typically are used when these pest populations have become so 

widespread that eradication or effective control would be difficult or no longer practical. 

Biological control has advantages as well as disadvantages. Benefits would include reducing 

pesticide usage, host specificity for target pests, long-term self-perpetuating control, low 

cost/acre, capacity for searching and locating hosts, synchronizing biological control agents to 

hosts’ life cycles, and the unlikelihood that hosts will develop resistance to agents. 

Disadvantages would include the following: limited availability of agents from their native 

lands, the dependence of control on target species density, slow rate at which control occurs, 

biotype matching, the difficulty and expense of conflicts over control of the target pest, and host 

specificity when host populations are low. 

A reduction in target species populations from biological controls is typically a slow process, and 

efficacy can be highly variable. It may not work well in a particular area although it does work 

well in other areas. Biological control agents would require specific environmental conditions to 

survive over time. Some of these conditions are understood; whereas, others are only partially 

understood or not at all. 

Biological control agents would not eradicate a target pest. When using biological control 

agents, residual levels of the target pest typically are expected; the agent population level or 

survival would be dependent upon the density of its host. After the pest population decreases, the 

population of the biological control agent would decrease correspondingly. This is a natural 

cycle. Some pest populations (e.g., invasive plants) would tend to persist for several years after a 

biological control agent becomes established due to seed reserves in the soil, inefficiencies in the 

agents search behavior, and the natural lag in population buildup of the agent. 

The full range of pest groups potentially found on refuge lands and waters would include 

diseases, invertebrates (insects, mollusks), vertebrates and invasive plants (most common group). 

Often it is assumed that biological control would address many if not most of these pest 

problems. Introduced species without desirable close relatives in the United States would 

generally be selected as biological controls. Natural enemies that are restricted to one or a few 

closely related plants in their country of origin are targeted as biological controls (Center et al. 

1997, Hasan and Ayres 1990). 
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The Hawai‘i Department of Agriculture (HDOA) has a highly successful bio-control program for 

the erythrina gall wasp which has resulted in the rebounding of the native wiliwili trees. In June 

2010, HDOA began another biological control program that releases a tiny parasitic insect to 

control the stinging Nettle Caterpillar. The release of Brazilian scale to slow the growth rate and 

spread of strawberry guava has recently been proposed to give Hawai‘i’s native plants a chance 

for survival, protect the ability of the forests to provide water, and provide better protection for 

agricultural crops from the fruit flies that breed in the overabundance of strawberry guava fruit. 

Due to the success of HDOA’s biocontrol programs, the State has become a leader in the world 

on the use of biological control to fight invasive pests. 

Refuge staff would ensure introduced agents are approved by the applicable authorities. Except 

for a small number of formulated biological control products registered by USEPA under FIFRA, 

most biological control agents are regulated by the U.S. Department of Agriculture (USDA)-

Animal Plant Health Inspection Service, Plant Protection and Quarantine (APHIS-PPQ). State 

departments of agriculture and, in some cases, county agricultural commissioners or weed 

districts, have additional approval authority. 

Federal permits (USDA-APHIS-PPQ Form 526) are required to import biocontrol agents from 

another State. Form 526 may be obtained by writing: 

 USDA-APHIS-PPQ 

 Biological Assessment and Taxonomic Support 

 4700 River Road, Unit 113 

 Riverdale, MD 20737 

or 

through the internet at URL address: 

http://www.aphis.usda.gov/ppq/permits/bioligical/weedbio.html. 

The Service strongly supports the development, and legal and responsible use of appropriate, 

safe, and effective biological control agents for nuisance and nonindigenous or pest species. 

State and county agriculture departments may also be sources for biological control agents or 

they may have information about where biological control agents may be obtained. Commercial 

sources should have an Application and Permit to Move Live Plant Pests and Noxious Weeds 

(USDA-PPQ Form 226 USDA-APHIS-PPQ, Biological Assessment and Taxonomic Support, 

4700 River Road, Unit 113, Riverdale, MD 20737) to release specific biological control agents in 

a State and/or county. Furthermore, certification regarding the biological control agent’s identity 

(genus, specific epithet, sub-species and variety) and purity (e.g., parasite free, pathogen free, and 

biotic and abiotic contaminants) should be specified in purchase orders. 

Biological control agents are subject to 569 FW 1. In addition, Refuge staff would follow the 

International Code of Best Practice for Classical Biological Control of Weeds 

(http://sric.ucdavis.edu/exotic /exotic.htm) as ratified by delegates to the X International 

Symposium on Biological Control of Weeds, Bozeman, MT, July 9, 1999. This code identifies 

the following: 

 Release only approved biological control agents, 

 Use the most effective agents, 
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E-8 Appendix E: Integrated Pest Management Program 

 Document releases, and 

 Monitor for impact to the target pest, nontarget species and the environment. 

Biological control agents formulated as pesticide products and registered by the USEPA (e.g., 

Bti) are also subject to PUP review and approval (see below). 

A record of all releases would be maintained with date(s), location(s), and environmental 

conditions of the release site(s); the identity, quantity, and condition of the biological control 

agents released; and other relevant data and comments such as weather conditions. Systematic 

monitoring to determine the establishment and effectiveness of the release is also recommended. 

NEPA documents regarding biological and other environmental effects of biological control 

agents prepared by another Federal agency, where the scope is relevant to evaluation of releases 

on Refuge lands, would be reviewed. Possible source agencies for such NEPA documents 

include the Bureau of Land Management (BLM), U.S. Forest Service, National Park Service, 

U.S. Department of Agriculture-Animal and Plant Health Inspection Service, and the military 

services. It might be appropriate to incorporate by reference parts or all of existing document(s) 

from the review. Incorporating by reference (43 CFR 46.135) is a technique used to avoid 

redundancies in analysis. It also can reduce the bulk of a Service NEPA document, which only 

must identify the documents that are incorporated by reference. In addition, relevant portions 

must be summarized in the Service NEPA document to the extent necessary to provide the 

decision maker and public with an understanding of relevance of the referenced material to the 

current analysis. 

 Pesticides. The selective use of pesticides would be based upon pest ecology (including mode of 

reproduction), the size and distribution of its populations, site-specific conditions (e.g., soils, 

topography), known efficacy under similar site conditions, and the capability to utilize best 

management practices (BMPs) to reduce/eliminate potential effects to nontarget species, sensitive 

habitats, and potential to contaminate surface and groundwater. All pesticide usage (pesticide, 

target species, application rate, and method of application) would comply with the applicable 

Federal (FIFRA) and State regulations pertaining to pesticide use, safety, storage, disposal, and 

reporting. Before pesticides can be used to eradicate, control, or contain pests on Refuge lands 

and waters, pesticide use proposals (PUPs) would be prepared and approved in accordance with 

569 FW 1. PUP records would provide a detailed, time-, site-, and target-specific description of 

the proposed use of pesticides on Refuge. All PUPs would be created, approved or disapproved, 

and stored in the Pesticide Use Proposal System (PUPS), which is a centralized database only 

accessible on the Service’s intranet (https://systems.fws.gov/pups). Only Service employees 

would be authorized to access PUP records for a Refuge in this database. 

Application equipment would be selected to provide site-specific delivery to target pests while 

minimizing/eliminating direct or indirect (e.g., drift) exposure to nontarget areas and degradation 

of surface and groundwater quality. Where possible, target-specific equipment (e.g., backpack 

sprayer, wiper) would be used to treat target pests. Other target-specific equipment to apply 

pesticides would include soaked wicks or paint brushes for wiping vegetation and lances, 

hatchets, or syringes for direct injection into stems. Granular pesticides may be applied using 

seeders or other specialized dispensers. In contrast, aerial spraying (e.g., fixed wing or 
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Appendix E: Integrated Pest Management Program E-9 

helicopter) would only be used where access is difficult (remoteness) and/or the size/distribution 

of infestations precludes practical use of ground-based methods. 

Because repeated use of one pesticide may allow resistant organisms to survive and reproduce, 

multiple pesticides with variable modes of action would be considered for treatments on Refuge 

lands and waters. If there is only one pesticide available to control a pest species its use will be 

balanced against the potential for species resistance. Indiscriminate use of a pesticide may result 

pest resistance and no effective control in the future. This is especially important if multiple 

applications within years and/or over a growing season likely would be necessary for habitat 

maintenance and restoration activities to achieve resource objectives. Integrated chemical and 

nonchemical controls also are highly effective, where practical, because pesticide resistant 

organisms can be removed from the site. 

Cost may not be the primary factor in selecting a pesticide for use on the Refuge. If the least 

expensive pesticide would potentially harm natural resources or people, then a different product 

would be selected, if available. The most efficacious pesticide available with the least potential 

to degrade environment quality (soils, surface water, and groundwater) as well as least potential 

effect to native species and communities of fish, wildlife, plants, and their habitats would be 

acceptable for use on Refuge lands in the context of an IPM approach. 

 Habitat restoration/maintenance. Restoration and/or proper maintenance of Refuge habitats 

associated with achieving wildlife and habitat objectives would be essential for long-term 

prevention, eradication, or control (at or below threshold levels) of pests. Promoting desirable 

plant communities through the manipulation of species composition, plant density, and growth 

rate is an essential component of invasive plant management (Masters et al. 1996, Masters and 

Shelly 2001, Brooks et al. 2004). The following three components of succession could be 

manipulated through habitat maintenance and restoration: site availability, species availability, 

and species performance (Cox and Anderson 2004). Although a single method (e.g., herbicide 

treatment) may eliminate or suppress pest species in the short term, the resulting gaps and bare 

soil create niches that are conducive to further invasion by the species and/or other invasive 

plants, including species that may be even more harmful than the target species. On degraded 

sites where desirable species are absent or in low abundance, revegetation with native/desirable 

grasses, forbs, and legumes may be necessary to direct and accelerate plant community recovery, 

and achieve site-specific objectives in a reasonable time frame. The selection of appropriate 

species for revegetation would be dependent on a number of factors including resource objectives 

and site-specific, abiotic factors (e.g., soil texture, soil moisture, precipitation/temperature 

regimes, and shade conditions). Seed availability and cost, ease of establishment, seed 

production, and competitive ability also would be important considerations. 

 Predator Control. The predator management plan for Keālia Pond NWR is implemented to 

reduce depredation of endangered waterbirds. Control measures would include indirect, nonlethal and lethal techniques in addition to prevention and direct control measures that would have 

minimal effects on the human environment. 

Indirect Measures at Keālia Pond NWR will include installation of a perimeter predator proof 

fence (Alternative C). In the absence of this fence, dense vegetation will remain to discourage 
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E-10 Appendix E: Integrated Pest Management Program 

visitors from disturbing endangered waterbirds and nesting areas will be temporarily closed to 

access. Cattle egret roost trees will be mechanically removed or treated with herbicides. 

Most cats and dogs will be removed by cage traps and transported to an animal shelter. Other 

predators (mongooses, rats) would be controlled by cage traps or humane lethal means. Control 

measures will minimize loss of non-target native wildlife. Except for nuisance alien species, all 

uninjured non-target species captured will be released near the site of capture or at a suitable 

location at the discretion of Refuge staff. 

Most of Keālia Pond NWR is closed to the public and posted. In public access areas (Kanuimanu 

Ponds, Keālia Coastal Boardwalk), most predator control measures will be conducted during the 

ae‘o nesting season and areas with active nests will also be closed. Rodenticides will be placed 

in tamper-resistant bait boxes and the area signed. Herbicide treatment of cattle egret roost trees 

will occur in closed areas of the Refuge. Egret control by firearms will occur when the Refuge is 

closed to the public. 

Direct Measures include a range of predator management equipment and methods . The 

preferred control method will be cage traps for dogs and cats. Mongooses and rodents will be 

controlled by a combination of cage traps, lethal traps, and rodenticides. Direct control of cattle 

egrets would be with firearms. In rare instances, a TimmsTM kill trap (a type of snap trap) or 

padded leghold trap would be used on cats that avoid cage traps. All cage traps will be checked 

every 48 hours or less. Except for continuous trapping (year-round) near the HQ/VC, trapping 

will occur seasonally just prior to the ae‘o nesting season through the end of the breeding/chick 

rearing period (April-September). Spot trapping may occur when signs of depredation of 

endangered species are observed outside the nesting season. Predator monitoring will occur 

throughout the year by direct observations, tracks, tracking tunnels, and trail cameras. Cage 

trapped dogs and cats will be transported to a local animal shelter. Any cage trapped birds will 

be released at the trap site. Live trapped mongooses will the euthanized using approved humane 

methods. 

4.0 Priorities for Treatments 

The magnitude (number, distribution, and sizes of infestations) for pest problems is too extensive and 

beyond the available capital resources to effectively address during any single field season. To 

manage pests in Refuge, it would be essential to prioritize treatment of infestations. Highest priority 

treatments would be focused on early detection and rapid response to eliminate infestations of new 

pests, if possible. This would be especially important for aggressive pests potentially impacting 

species, species groups, communities, and/or habitats associated Refuge purpose(s), System 

resources of concern (federally listed species, migratory birds, selected marine mammals, and 

interjurisdictional fish), and native species for maintaining/restoring biological integrity, diversity, 

and environmental health. 

The next priority would be treating established pests that appear in one or more previously uninfested 

areas. Moody and Mack (1988) demonstrated through modeling that small, new outbreaks of 

invasive plants eventually would infest an area larger than the established, source population. They 

also found that control efforts focusing on the large, main infestation rather than the new, small 

satellites reduced the chances of overall success. The lowest priority would be treating large 
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infestations (sometimes monotypic stands) of well-established pests. In this case, initial efforts 

would focus upon containment of the perimeter followed by work to control/eradicate the established 

infested area. If containment and/or control of a large infestation is not effective, then efforts would 

focus upon halting pest reproduction or managing source populations. Maxwell et al. (2009) found 

treating fewer populations that are sources represents an effective long-term strategy to reduce of 

total number of invasive populations and decreasing meta-population growth rates. 

Although State listed noxious weeds would always of high priority for management, other pest 

species known to cause substantial ecological impact would also be considered. For example, shortspined kiawe may not be listed by a State as noxious, but it can greatly alter fire regimes in the 

coastal dryland shrub habitat resulting in large monotypic stands that displace native bunch grasses, 

forbs, and shrubs. Pest control would likely require a multi-year commitment from Refuge staff. 

Essential to the long-term success of pest management would be pre- and post-treatment monitoring, 

assessment of the successes and failures of treatments, and development of new approaches when 

proposed methods do not achieve desired outcomes. 

5.0 Best Management Practices (BMPs) 

BMPs can minimize or eliminate possible effects associated with pesticide usage to nontarget species 

and/or sensitive habitats as well as degradation of water quality from drift, surface runoff, or 

leaching. Based upon the Department of the Interior Pesticide Use Policy (517 DM 1) and the 

Service Pest Management Policy and Responsibilities (30 AM 12), the use of applicable BMPs 

(where feasible) also would likely ensure that pesticide uses may not adversely affect federally listed 

species and/or their critical habitats through determinations made using the process described in 

50 CFR part 402. 

The following are BMPs pertaining to mixing/handling and applying pesticides for all ground-based 

treatments of pesticides, which would be considered and utilized, where feasible, based upon targetand site-specific factors and time-specific environmental conditions. Although not listed below, the 

most important BMP to eliminate/reduce potential impacts to nontarget resources would be an IPM 

approach to prevent, control, eradicate, and contain pests. 

5.1 Pesticide Handling and Mixing 

 As a precaution against spilling, spray tanks would not be left unattended during filling. 

 All pesticide containers would be triple rinsed and the rinsate would be used as water in the 

sprayer tank and applied to treatment areas. 

 All pesticide spray equipment would be properly cleaned. Where possible, rinsate would be used 

as part of the make-up water in the sprayer tank and applied to treatment areas. 

 Refuge staff would empty, triple rinsed pesticide containers that can be recycled at local 

herbicide container collections. 

 All unused pesticides would be properly discarded at a local “safe send” collection. 

 Pesticides and pesticide containers would be lawfully stored, handled, and disposed of in 

accordance with the label and in a manner safeguarding human health, fish, and wildlife and 

prevent soil and water contaminanation. 

 Refuge staff would consider the water quality parameters (e.g., pH, hardness) that are important 

to ensure greatest efficacy where specified on the pesticide label. 

 All pesticide spills would be addressed immediately using procedures identified in Refuge spill 
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E-12 Appendix E: Integrated Pest Management Program 

respond plan. 

5.2 Applying Pesticides 

 Pesticide treatments would only be conducted by or under the supervision of Service personnel 

and non-Service applicators with the appropriate, State or BLM certification to safely and 

effectively conduct these activities on Refuge lands and waters. 

 Refuge staff would comply with all Federal, State, and local pesticide use laws and regulations as 

well as Service pesticide-related policies. For example, Refuge staff would use application 

equipment and apply rates for the specific pest(s) identified on the pesticide label as required 

under FIFRA. 

 Before each treatment season and prior to mixing or applying any product for the first time each 

season, all applicators would review the labels, MSDSs, and Pesticide Use Proposal (PUPs) for 

each pesticide, determining the target pest, appropriate mix rate(s), PPE, and other requirements 

listed on the pesticide label. 

 A 1’ no-spray buffer from the water’s edge would be used, where applicable, and it does not 

detrimentally influence effective control of pest species. 

 Use low impact herbicide application techniques (e.g., spot treatment, cut stump, oil basal, 

Thinvert system applications) rather than broadcast foliar applications (e.g., boom sprayer, other 

larger tank wand applications), where practical. 

 Use low volume rather than high volume foliar applications where low impact methods above are 

not feasible or practical, to maximize herbicide effectiveness and ensure correct and uniform 

application rates. 

 Applicators would use and adjust spray equipment to apply the coarsest droplet size spectrum 

with optimal coverage of the target species while reducing drift. 

 Applicators would use the largest droplet size that results in uniform coverage. 

 Applicators would use drift reduction technologies such as low-drift nozzles, where possible. 

 Where possible, spraying would occur during low (average<7mph and preferably 3-5 mph) and 

consistent direction wind conditions with moderate temperatures (typically <85 oF). 

 Where possible, applicators would avoid spraying during inversion conditions (often associated 

with calm and very low wind conditions) that can cause large-scale herbicide drift to nontarget 

areas. 

 Equipment would be calibrated regularly to ensure that the proper rate of pesticide is applied to 

the target area or species. 

 Spray applications would be made at the lowest height for uniform coverage of target pests to 

minimize/eliminate potential drift. 

 If windy conditions frequently occur during afternoons, spraying (especially boom treatments) 

would typically be conducted during early morning hours. 

 Spray applications would not be conducted on days with >30% forecast for rain within 6 hours, 

except for pesticides that are rapidly rain fast (e.g., glyphosate in 1 hour) to minimize/eliminate 

potential runoff. 

 Where possible, applicators would use drift retardant adjuvants during spray applications, 

especially adjacent to sensitive areas. 

 Where possible, applicators would use a nontoxic dye to aid in identifying target area treated as 

well as potential over spray or drift. A dye can also aid in detecting equipment leaks. If a leak is 

discovered, the application would be stopped until repairs can be made to the sprayer. 
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 For pesticide uses associated with facilities management, buffers, as appropriate, would be used 

to protect sensitive habitats, especially wetlands and other aquatic habitats. 

 When drift cannot be sufficiently reduced through altering equipment set up and application 

techniques, buffer zones may be identified to protect sensitive areas downwind of applications. 

Refuge staff would only apply adjacent to sensitive areas when the wind is blowing the opposite 

direction. 

 Applicators would utilize scouting for early detection of pests to eliminate unnecessary pesticide 

applications. 

 Refuge staff would consider timing of application so native plants are protected (e.g., 

senescence) while effectively treating invasive plants. 

 Rinsate from cleaning spray equipment after application would be recaptured and reused or 

applied to an appropriate pest plant infestation. 

 Application equipment (e.g., sprayer, ATV, tractor) would be thoroughly cleaned and PPE would 

be removed/disposed of on-site by applicators after treatments to eliminate the potential spread of 

pests to un-infested areas. 

6.0 Safety 

6.1 Personal Protective Equipment 

All applicators would wear the specific personal protective equipment (PPE) identified on the 

pesticide label. The appropriate PPE will be worn at all times during handling, mixing, and applying. 

PPE can include the following: disposable (e.g., Tyvek) or laundered coveralls; gloves (latex, 

rubber, or nitrile); rubber boots; and/or an NIOSH-approved respirator. Because exposure to 

concentrated product is usually greatest during mixing, extra care should be taken while preparing 

pesticide solutions. Persons mixing these solutions can be best protected if they wear long gloves, an 

apron, footwear, and a face shield. 

Coveralls and other protective clothing used during an application would be laundered separately 

from other laundry items. Transporting, storing, handling, mixing and disposing of pesticide 

containers will be consistent with label requirements, USEPA and OSHA requirements, and Service 

policy. 

If a respirator is necessary for a pesticide use, then the following requirements would be met in 

accordance with Service safety policy: a written Respirator Program, fit testing, physical 

examination (including pulmonary function and blood work for contaminants), and proper storage of 

the respirator. 

6.2 Notification 

The restricted entry interval (REI) is the time period required after the application at which point 

someone may safely enter a treated area without PPE. Refuge staff, authorized management agents 

of the Service, volunteers, and members of the public who could be in or near a pesticide treated area 

within the stated re-entry time period on the label would be notified about treatment areas. Posting 

would occur at any site where individuals might inadvertently become exposed to a pesticide during 

other activities on the Refuge. Where required by the label and/or State-specific regulations, sites 

would also be posted on its perimeter and at other likely locations of entry. Refuge staff would also 

notify appropriate private property owners of an intended application, including any private 

individuals have requested notification. Special efforts would be made to contact nearby individuals 
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E-14 Appendix E: Integrated Pest Management Program 

who are beekeepers or who have expressed chemical sensitivities. 

6.3 Medical Surveillance 

Medical surveillance may be required for Service personnel and approved volunteers who mix, 

apply, and/or monitor use of pesticides (see 242 FW 7 [Pesticide Users] and 242 FW 4 [Medical 

Surveillance]). In accordance with 242 FW 7.12A, Service personnel would be medically 

monitoring if 1 or more of the following criteria is met: exposed or may be exposed to 

concentrations at or above the published permissible exposure limits or threshold limit values (see 

242 FW 4); use pesticides in a manner considered “frequent pesticide use”; or use pesticides in a 

manner that requires a respirator (see 242 FW 14 for respirator use requirements). In 242 FW7.7A, 

“Frequent Pesticide Use” means when a person applying pesticide handles, mixes, or applies 

pesticides, with a Health Hazard rating of 3 or higher, for 8 or more hours in any week or 16 or more 

hours in any 30-day period.” Under some circumstances, individuals may be medically monitored 

who use pesticides infrequently (see section 7.7), experience an acute exposure (sudden, short term), 

or use pesticides with a health hazard ranking of 1 or 2. This decision would consider the 

individual’s health and fitness level, the pesticide’s specific health risks, and the potential risks from 

other pesticide-related activities. Refuge cooperators and other authorized agents (e.g., State and 

County employees) would be responsible for their own medical monitoring needs and costs. 

Standard examinations (at Refuge expense) of appropriate Refuge staff would be provided by the 

nearest certified occupational health and safety physician as determined by Federal Occupational 

Health. 

6.4 Certification and Supervision of Pesticide Applicators 

Appropriate Refuge staff or approved volunteers handling, mixing, and/or applying or directly 

supervising others engaged in pesticide use activities would be trained and State or federally licensed 

to apply pesticides to Refuge lands or waters. In accordance with 242 FW7.18A and 569 FW 1, 

certification is required to apply restricted use pesticides based upon USEPA regulations. For safety 

reasons, all individuals participating in pest management activities with general use pesticides also 

are encouraged to attend appropriate training or acquire pesticide applicator certification. The 

certification requirement would be for a commercial or private applicator depending upon the State. 

New staff unfamiliar with proper procedures for storing, mixing, handling, applying, and disposing 

of herbicides and containers would receive orientation and training before handling or using any 

products. Documentation of training would be kept in the files at the Refuge office. 

6.5 Record Keeping 

Labels and material safety data sheets 

Pesticide labels and material safety data sheets (MSDSs) would be maintained at the Refuge shop 

and laminated copies in the mixing area. These documents also would be carried by field 

applicators, where possible. A written reference (e.g., note pad, chalk board, dry erase board) for 

each tank to be mixed would be kept in the mixing area for quick reference while mixing is in 

progress. In addition, approved PUPs stored in the PUPS database typically contain website links 

(URLs) to pesticide labels and MSDSs. 

 
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Appendix E: Integrated Pest Management Program E-15 

Pesticide use proposals (PUPs) 

A PUP would be prepared for each proposed pesticide use associated with annual pest management 

on Refuge lands and waters. A PUP would include specific information about the proposed pesticide 

use including the common and chemical names of the pesticide(s), target pest species, size and 

location of treatment site(s), application rate(s) and method(s), and federally listed species 

determinations, where applicable. 

In accordance with 30 AM 12 and 7 RM 14, PUPs would be required for the following: 

 Uses of pesticides on lands and facilities owned or managed by the Service, including properties 

managed by Service personnel as a result of the Food Security Act of 1985; 

 Service projects by non-Service personnel on Service owned or controlled lands and facilities and 

other pest management activities that would be conducted by Service personnel; and 

 Where the Service would be responsible or provides funds for pest management identified in 

protective covenants, easements, contracts, or agreements off Service lands. 

In accordance with Service guidelines (Director’s memo [December 12, 2007]), Refuge staff may 

receive up to 5-year approvals for Washington Office and field reviewed proposed pesticide uses 

based upon meeting identified criteria including an approved IPM plan, where necessary (see 

http://www.fws.gov/contaminants/Issues/IPM.cfm). For a refuge, an IPM plan (requirements 

described herein) can be completed independently or in association with a CCP or HMP if IPM 

strategies and potential environmental effects are adequately addressed within appropriate NEPA 

documentation. 

PUPs would be created, approved or disapproved, and stored as records in the Pesticide Use Proposal 

System (PUPS), which is centralized database on the Service’s intranet 

(https://systems.fws.gov/pups). Only Service employees can access PUP records in this database. 

Pesticide usage 

In accordance with 569 FW 1, the Refuge Project Leader would be required to maintain records of all 

pesticides annually applied on lands or waters under Refuge jurisdiction. This would encompass 

pesticides applied by other Federal agencies, State and county governments, nongovernment 

applicators including cooperators and their pest management service providers with Service 

permission. For clarification, pesticide means all insecticides, insect and plant growth regulators, 

dessicants, herbicides, fungicides, rodenticides, acaricides, nematicides, fumigants, avicides, and 

piscicides. 

The following usage information can be reported for approved PUPs in the PUPS database: 

 Pesticide trade name(s) 

 Active ingredient(s) 

 Total acres treated 

 Total amount of pesticides used (lbs or gallons) 

 Total amount of active ingredient(s) used (lbs) 

 Target pest(s) 

 Efficacy (% control) 

To determine whether treatments are efficacious (eradicating, controlling, or containing the target 

pest) and achieving resource objectives, habitat and/or wildlife response would be monitored both 
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E-16 Appendix E: Integrated Pest Management Program 

pre- and post-treatment, where possible. Considering available annual funding and staffing, 

appropriate monitoring data regarding characteristics (attributes) of pest infestations (e.g., area, 

perimeter, degree of infestation-density, % cover, density) as well as habitat and/or wildlife response 

to treatments may be collected and stored in a relational database (e.g., Refuge Habitat Management 

Database), preferably a geo-referenced data management system (e.g., Refuge Lands GIS [RLGIS]) 

to facilitate data analyses and subsequent reporting. In accordance with adaptive management, data 

analysis and interpretation would allow treatments to be modified or changed over time, as 

necessary, to achieve resource objectives considering site-specific conditions in conjunction with 

habitat and/or wildlife responses. Monitoring could also identify short- and long-term impacts to 

natural resources and environmental quality associated with IPM treatments in accordance with 

adaptive management principles identified in 43 CFR 46.145. 

7.0 Evaluating Pesticide Use Proposals 

Pesticides would only be used on Refuge lands for habitat management as well as facilities 

maintenance after approval of a PUP. In general, proposed pesticide uses on Refuge lands would 

only be approved where there would likely be minor, temporary, or localized effects to fish and 

wildlife species as well as minimal potential to degrade environmental quality. Potential effects to 

listed and nonlisted species would be evaluated with quantitative ecological risk assessments and 

other screening measures. Potential effects to environmental quality would be based upon pesticide 

characteristics of environmental fate (water solubility, soil mobility, soil persistence, and 

volatilization) and other quantitative screening tools. Ecological risk assessments as well as 

characteristics of environmental fate and potential to degrade environmental quality for pesticides 

would be documented in Chemical Profiles (see Section 7.5). These profiles would include threshold 

values for quantitative measures of ecological risk assessments and screening tools for environmental 

fate that represent minimal potential effects to species and environmental quality. In general, only 

pesticide uses with appropriate BMPs (see Section 4.0) for habitat management and facilities 

maintenance on Refuge lands that would potentially have minor, temporary, or localized effects on 

Refuge biological and environmental quality (threshold values not exceeded) would be approved. 

7.1 Overview of Ecological Risk Assessment 

An ecological risk assessment process would be used to evaluate potential adverse effects to 

biological resources as a result of a pesticide(s) proposed for use on Refuge lands. It is an 

established quantitative and qualitative methodology for comparing and prioritizing risks of 

pesticides and conveying an estimate of the potential risk for an adverse effect. This quantitative 

methodology provides an efficient mechanism to integrate best available scientific information 

regarding hazard, patterns of use (exposure), and dose-response relationships in a manner that is 

useful for ecological risk decision-making. It would provide an effective way to evaluate potential 

effects where there is missing or unavailable scientific information (data gaps) to address reasonable, 

foreseeable adverse effects in the field as required under 40 CFR Part 1502.22. Protocols for 

ecological risk assessment of pesticide uses on the Refuge were developed through research and 

established by the US Environmental Protection Agency (USEPA). Assumptions for these risk 

assessments are presented in Section 6.2.3. 

The toxicological data used in ecological risk assessments are typically results of standardized 

laboratory studies provided by pesticide registrants to the USEPA to meet regulatory requirements 

under the Federal Insecticide, Fungicide and Rodenticide Act of 1996 (FIFRA). These studies assess 
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Appendix E: Integrated Pest Management Program E-17 

the acute (lethality) and chronic (reproductive) effects associated with short- and long-term exposure 

to pesticides on representative species of birds, mammals, freshwater fish, aquatic invertebrates, and 

terrestrial and aquatic plants. Other effects data publicly available would also be utilized for risk 

assessment protocols described herein. Toxicity endpoint and environmental fate data are available 

from a variety of resources (Section 7.6). 

Table E.1. Ecotoxicity tests used to evaluate potential effects to birds, fish, and mammals to establish toxicity 

endpoints for risk quotient calculations. 

Species Group Exposure Measurement endpoint 

Bird 

Acute Median Lethal Concentration (LC50) 

Chronic No Observed Effect Concentration (NOEC) or 

No Observed Adverse Effect Concentration (NOAEC)1 

Fish 

Acute Median Lethal Concentration (LC50) 

Chronic No Observed Effect Concentration (NOEC) or 

No Observed Adverse Effect Concentration (NOAEC)2

Mammal Acute Oral Lethal Dose (LD50) 

Chronic No Observed Effect Concentration (NOEC) or 

No Observed Adverse Effect Concentration (NOAEC)3

1

Measurement endpoints typically include a variety of reproductive parameters (e.g., number of 

eggs, number of offspring, eggshell thickness, and number of cracked eggs). 

2

Measurement endpoints for early life stage/life cycle typically include embryo hatch rates, time 

to hatch, growth, and time to swim-up. 

3

Measurement endpoints include maternal toxicity, teratogenic effects or developmental 

anomalies, evidence of mutagenicity or genotoxicity, and interference with cellular mechanisms 

such as DNA synthesis and DNA repair. 

7.2 Determining Ecological Risk to Fish and Wildlife 

The potential for pesticides used on the Refuge to cause direct adverse effects to fish and wildlife 

would be evaluated using USEPA’s Ecological Risk Assessment Process (USEPA 2004). This 

deterministic approach, which is based upon a two-phase process involving estimation of 

environmental concentrations and then characterization of risk, would be used for ecological risk 

assessments. This method integrates exposure estimates (estimated environmental concentration 

[EEC] and toxicological endpoints [e.g., LC50 and oral LD50]) to evaluate the potential for adverse 

effects to species groups (birds, mammals, and fish) representative of legal mandates for managing 

units of the NWRS. This integration is achieved through risk quotients (RQs) calculated by dividing 

the EEC by acute and chronic toxicity values selected from standardized toxicological endpoints or 

published effect (Table 1). 

RQ = EEC/Toxicological Endpoint 

The level of risk associated with direct effects of pesticide use would be characterized by comparing 

calculated RQs to the appropriate Level of Concern (LOC) established by USEPA (1998 [Table 2]). 

The LOC represents a quantitative threshold value for screening potential adverse effects to fish and 

wildlife resources associated with pesticide use. The following are four exposure-species group 

scenarios that would be used to characterize ecological risk to fish and wildlife on the Refuge: acutelisted species, acute-nonlisted species, chronic-listed species, and chronic-nonlisted species. 
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Acute risk would indicate the potential for mortality associated with short-term dietary exposure to 

pesticides immediately after an application. For characterization of acute risks, median values from 

LC50 and LD50 tests would be used as toxicological endpoints for RQ calculations. In contrast, 

chronic risks would indicate the potential for adverse effects associated with long-term dietary 

exposure to pesticides from a single application or multiple applications over time (within a season 

and over years). For characterization of chronic risks, the no observed concentration (NOAEC) or no 

observed effect concentration (NOEC) for reproduction would be used as toxicological endpoints for 

RQ calculations. Where available, the NOAEC would be preferred over a NOEC value. 

Listed species are those federally designated as threatened, endangered, or proposed in accordance 

with the Endangered Species Act of 1973 (16 USC 1531-1544, 87 Stat. 884, as amended-Public Law 

93-205). For listed species, potential adverse effects would be assessed at the individual level 

because loss of individuals from a population could detrimentally impact a species. In contrast, risks 

to nonlisted species would consider effects at the population level. A RQ<LOC would indicate the 

proposed pesticide use “may affect, not likely to adversely effect” individuals (listed species) and it 

would not pose an unacceptable risk for adverse effects to populations (nonlisted species) for each 

taxonomic group (Table E.2). In contrast, a RQ>LOC would indicate a “may affect, likely to 

adversely affect” for listed species and it would also pose unacceptable ecological risk for adverse 

effects to nonlisted species. 

 

Table E.2. Presumption of unacceptable risk for birds, fish, and mammals (US EPA 1998). 

Risk Presumption Level of Concern 

Listed Species Nonlisted Species 

Acute Birds 0.1 0.5 

Fish 0.05 0.5 

Mammals 0.1 0.5 

Chronic Birds 1.0 1.0 

Fish 1.0 1.0 

Mammals 1.0 1.0 

Environmental exposure 

Following release into the environment through application, pesticides would experience several 

different routes of environmental fate. Pesticides which would be sprayed can move through the air 

(e.g., particle or vapor drift) and may eventually end up in other parts of the environment such as 

nontarget vegetation, soil, or water. Pesticides applied directly to the soil may be washed off the soil 

into nearby bodies of surface water (e.g., surface runoff) or may percolate through the soil to lower 

soil layers and groundwater (e.g., leaching) (Baker and Miller 1999, Pope et. al. 1999, Butler et. al. 

1998, Ramsay et. al. 1995, EXTOXNET 1993a). Pesticides which would be injected into the soil 

may also be subject to the latter two fates. The aforementioned possibilities are by no means 

complete, but it does indicate movement of pesticides in the environment is very complex with 

transfers occurring continually among different environmental compartments. In some cases, these 

exchanges occur not only between areas that are close together, but it also may involve transportation 

of pesticides over long distances (Barry 2004, Woods 2004). 

Terrestrial exposure 

The estimated environmental concentration (ECC) for exposure to terrestrial wildlife would be 

quantified using an USEPA screening-level approach (USEPA 2004). This screening-level 
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Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix E: Integrated Pest Management Program E-19 

approach is not affected by product formulation because it evaluates pesticide active ingredient(s). 

This approach would vary depending upon the proposed pesticide application method: spray or 

granular. 

Terrestrial-spray application 

For spray applications, exposure would be determined using the Kanaga nomogram method (USEPA 

2005a, USEPA 2004, Pfleeger et al. 1996) through the USEPA’s Terrestrial Residue Exposure 

model (T-REX) version 1.2.3 (USEPA 2005b). To estimate the maximum (initial) pesticide residue 

on short grass (<8”m tall) as a general food item category for terrestrial vertebrate species, T-REX 

input variables would include the following from the pesticide label: maximum pesticide application 

rate (pounds active ingredient [acid equivalent]/acre) and pesticide half-life (days) in soil. Although 

there are other food item categories (tall grasses; broadleaf plants and small insects; and fruits, pods, 

seeds and large insects), short grass was selected because it would yield maximum EECs (240 ppm 

per lb ai/acre) for worse-case risk assessments. Short grass is not representative of forage for 

carnivorous species (e.g., raptors), but it would characterize the maximum potential exposure through 

the diet of avian and mammalian prey items. Consequently, this approach would provide a 

conservative screening tool for pesticides that do not biomagnify. 

For RQ calculations in T-REX, the model would require the weight of surrogate species and Mineau 

scaling factors (Mineau et. al. 1996). Body weights of bobwhite quail and mallard are included in TREX by default, but body weights of other organisms (Table e.3) would be entered manually. The 

Mineau scaling factor accounts for small-bodied bird species that may be more sensitive to pesticide 

exposure than would be predicted only by body weight. Mineau scaling factors would be entered 

manually with values ranging from 1 to 1.55 that are unique to a particular pesticide or group of 

pesticides. If specific information to select a scaling factor is not available, then a value of 1.15 

would be used as a default. Alternatively, zero would be entered if it is known that body weight does 

not influence toxicity of pesticide(s) being assessed. The upper bound estimate output from the TREX Kanaga nomogram would be used as an EEC for calculation of RQs. This approach would 

yield a conservative estimate of ecological risk. 

Table E.3. Average body weight of selected terrestrial wildlife species frequently used in research to establish 

toxicological endpoints (Dunning 1984). 

Species Body Weight (kg) 

Mammal (15 g) 0.015 

House sparrow 0.0277 

Mammal (35 g) 0.035 

Starling 0.0823 

Red-winged blackbird 0.0526 

Common grackle 0.114 

Japanese quail 0.178 

Bobwhite quail 0.178 

Rat 0.200 

Rock dove (aka pigeon) 0.542 

Mammal (1000 g) 1.000 

Mallard 1.082 

Ring-necked pheasant 1.135 
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E-20 Appendix E: Integrated Pest Management Program 

Terrestrial – granular application 

Granular pesticide formulations and pesticide-treated seed would pose a unique route of exposure for 

avian and mammalian species. The pesticide is applied in discrete units which birds or mammals 

might ingest accidentally with food items or intentionally as in the case of some bird species actively 

seeking and picking up gravel or grit to aid digestion or seed as a food source. Granules may also be 

consumed by wildlife foraging on earthworms, slugs or other soft-bodied soil organisms to which the 

granules may adhere. 

Terrestrial wildlife RQs for granular formulations or seed treatments would be calculated by dividing 

the maximum milligrams of active ingredient (ai) exposed (e.g., EEC) on the surface of an area equal 

to 1 square foot by the appropriate LD50 value multiplied by the surrogate’s body weight (Table 3). 

An adjustment to surface area calculations would be made for broadcast, banded, and in-furrow 

applications. An adjustment also would be made for applications with and without incorporation of 

the granules. Without incorporation, it would be assumed that 100% of the granules remain on the 

soil surface available to foraging birds and mammals. Press wheels push granules flat with the soil 

surface, but they are not incorporated into the soil. If granules are incorporated in the soil during 

band or T-band applications or after broadcast applications, it would be assumed only 15% of the 

applied granules remain available to wildlife. It would be assumed that only 1% of the granules are 

available on the soil surface following in-furrow applications. 

EECs for pesticides applied in granular form and as seed treatments would be determined 

considering potential ingestion rates of avian or mammalian species (e.g., 10-30% body weight/day). 

This would provide an estimate of maximum exposure that may occur as a result of granule or seed 

treatment spills such as those that commonly occur at end rows during application and planting. The 

availability of granules and seed treatments to terrestrial vertebrates would also be considered by 

calculating the loading per unit area (LD50/ft2

)for comparison to USEPA Level of Concerns (USEPA 

1998). The T-REX version 1.2.3 (USEPA 2005b) contains a submodel which automates Kanaga 

exposure calculations for granular pesticides and treated seed. 

The following formulas will be used to calculate EECs depending upon the type of granular pesticide 

application: 

• In-furrow applications assume a typical value of 1% granules, bait, or seed remain 

unincorporated. 

mg a.i./ft.

2 

= [(lbs. product/acre)(% a.i.)(453,580 mg/lbs)(1% exposed))] / {[(43,560 ft.

2

/acre)/(row 

spacing (ft.))] / (row spacing (ft.)} 

or 

mg a.i./ft

2 

= [(lbs product/1000 ft. row)(% a.i.)(1000 ft row)(453,580 mg/lb.)(1% exposed) 

EEC = [(mg a.i./ft.

2

)(% of pesticide biologically available)] 

 Incorporated banded treatments assume that 15% of granules, bait, seeds are unincorporated. 

mg a.i./ft.

2 

= [(lbs. product/1000 row ft.)(% a.i.)(453,580 mg/lb.)(1-% incorporated)] / (1,000 

ft.)(band width (ft.)) 

EEC = [(mg a.i./ft.

2

)(% of pesticide biologically available)] 
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Appendix E: Integrated Pest Management Program E-21 

• Broadcast treatment without incorporation assumes 100% of granules, bait, seeds are 

unincorporated. 

mg a.i./ft.

2 

= [(lbs. product/acre)(% a.i.)(453,590 mg/lb.)] / (43,560 ft.

2

/acre) 

EEC = [(mg a.i./ft.

2

)(% of pesticide biologically available)] 

Where: 

• % of pesticide biologically available = 100% without species specific ingestion rates 

• Conversion for calculating mg a.i./ft.

2 

using ounces: 453,580 mg/lb. /16 = 28,349 mg/oz. 

The following equation would used to calculate a RQ based on the EEC calculated by one of the 

above equations. The EEC would divided by the surrogate LD50 toxicological endpoint multiplied by 

the body weight (Table 3) of the surrogate. 

RQ = EEC / [LD50 (mg/kg) * body weight (kg)] 

As with other risk assessments, a RQ>LOC would be a presumption of unacceptable ecological risk. 

A RQ<LOC would be a presumption of acceptable risk with only minor, temporary, or localized 

effects to species. 

Aquatic exposure 

Exposures to aquatic habitats (e.g., wetlands, meadows, ephemeral pools, water delivery ditches) 

would be evaluated separately for ground-based pesticide treatments of habitats managed for fish and 

wildlife compared with cropland/facilities maintenance. The primary exposure pathway for aquatic 

organisms from any ground-based treatments likely would be particle drift during the pesticide 

application. However, different exposure scenarios would be necessary as a result of contrasting 

application equipment and techniques as well as pesticides used to control pests on agricultural lands 

and facilities maintenance (e.g., roadsides, parking lots, trails) compared with other managed habitats 

on the Refuge. In addition, pesticide applications may be done <25’of the high water mark of 

aquatic habitats for habitat management treatments; whereas, no-spray buffers (≥25’) would be used 

for facilities maintenance treatments. 

Table E.4. Estimated Environmental Concentrations (ppb) of pesticides in aquatic habitats (1’ depth) 

immediately after direct application (Urban and Cook 1986). 

Lbs/acre EEC (ppb) 

0.10 36.7 

0.20 73.5 

0.25 91.9 

0.30 110.2 

0.40 147.0 

0.50 183.7 

0.75 275.6 

1.00 367.5 

1.25 459.7 

1.50 551.6 

1.75 643.5 

2.00 735.7 
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E-22 Appendix E: Integrated Pest Management Program 

2.25 827.6 

2.50 919.4 

3.00 1103.5 

4.00 1471.4 

5.00 1839 

6.00 2207 

7.00 2575 

8.00 2943 

9.00 3311 

10.00 3678 

Habitat treatments 

For the worst-case exposure scenario to nontarget aquatic habitats, EECs (Table E. 4) would be 

would be derived from Urban and Cook (1986) that assumes an intentional overspray to an entire, 

nontarget water body (1-foot depth) from a treatment <25’ from the high water mark using the max 

application rate (acid basis [see above]). However, use of BMPs for applying pesticides (see Section 

4.2) would likely minimize/eliminate potential drift to nontarget aquatic habitats during actual 

treatments. If there would be unacceptable (acute or chronic) risk to fish and wildlife with the 

simulated 100% overspray (RQ>LOC), then the proposed pesticide use may be disapproved or the 

PUP would be approved at a lower application rate to minimize/eliminate unacceptable risk to 

aquatic organisms (RQ=LOC). 

 Facilities maintenance treatments 

Field drift studies conducted by the Spray Drift Task Force, which is a joint project of several 

agricultural chemical businesses, were used to develop a generic spray drift database. From this 

database, the AgDRIFT computer model was created to satisfy USEPA pesticide registration spray 

drift data requirements and as a scientific basis to evaluate off-target movement of pesticides from 

particle drift and assess potential effects of exposure to wildlife. Several versions of the computer 

model have been developed (i.e., v2.01 through v2.10). The Spray Drift Task Force AgDRIFT® 

model version 2.01 (SDTF 2003, AgDRIFT 2001) would be used to derive EECs resulting from drift 

of pesticides to Refuge aquatic resources from ground-based pesticide applications >25’ from the 

high water mark. The Spray Drift Task Force AgDRIFT model is publicly available at 

http://www.agdrift.com. At this website, click “AgDRIFT 2.0” and then click “Download Now” and 

follow the instructions to obtain the computer model. 

The AgDRIFT model is composed of submodels called tiers. Tier I Ground submodel would be used 

to assess ground-based applications of pesticides. Tier outputs (EECs) would be calculated with 

AgDRIFT using the following input variables: max application rate (acid basis [see above]), low 

boom (20”), fine to medium droplet size, EPA-defined wetland, and a 

≥25-foot distance (buffer) from treated area to water. 

7.2.2 Use of information on effects of biological control agents, pesticides, degradates, and 

adjuvants 

NEPA documents regarding biological and other environmental effects of biological control agents, 

pesticides, degradates, and adjuvants prepared by another Federal agency, where the scope would be 

relevant to evaluation of effects from pesticide uses on Refuge lands, would be reviewed. Possible 

source agencies for such NEPA documents would include the BLM , US Forest Service, National 

Park Service, US Department of Agriculture-Animal and Plant Health Inspection Service, and the 
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Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix E: Integrated Pest Management Program E-23 

military services. It might be appropriate to incorporate by reference parts or all of existing 

document(s). Incorporating by reference (40 CFR 1502.21) is a technique used to avoid 

redundancies in analysis. It also would reduce the bulk of a Service NEPA document, which only 

would identify the documents that are incorporated by reference. In addition, relevant portions 

would be summarized in the Service NEPA document to the extent necessary to provide the decision 

maker and public with an understanding of relevance of the referenced material to the current 

analysis. 

In accordance with the requirements set forth in 43 CFR 46.135, the Service would specifically 

incorporate through reference ecological risk assessments prepared by the US Forest Service 

(http://www.fs.fed.us/r6/invasiveplant-eis/Risk-Assessments/Herbicides-Analyzed-InvPlantEIS.htm) and BLM (http://www.blm.gov/wo/st/en/prog/more/veg_eis.html). These risk assessments 

and associated documentation also are available in total with the administrative record for the Final 

Environmental Impact Statement entitled Pacific Northwest Region Invasive Plant Program – 

Preventing and Managing Invasive Plants (US Forest Service 2005) and Vegetation Treatments 

Using Herbicides on Bureau of Land Management Lands in 17 Western States Programmatic EIS 

(PEIS) (BLM 2007). In accordance with 43 CFR 46.120(d), use of existing NEPA documents by 

supplementing, tiering to, incorporating by reference, or adopting previous NEPA environmental 

analyses would avoid redundancy and unnecessary paperwork. 

As a basis for completing “Chemical Profiles” for approving or disapproving Refuge PUPs, 

ecological risk assessments for the following herbicide and adjuvant uses prepared by the US Forest 

Service would be incorporated by reference: 

 2,4-D 

 Chlorosulfuron 

 Clopyralid 

 Dicamba 

 Glyphosate 

 Imazapic 

 Imazapyr 

 Metsulfuron methyl 

 Picloram 

 Sethoxydim 

 Sulfometuron methyl 

 Triclopyr 

 Nonylphenol polyethylate (NPE) based surfactants 

As a basis for completing “Chemical Profiles” for approving or disapproving Refuge PUPs, 

ecological risk assessments for the following herbicide uses as well as evaluation of risks associated 

with pesticide degradates and adjuvants prepared by the BLM would be incorporated by reference: 

 Bromacil 

 Chlorsulfuron 

 Diflufenzopyr 

 Diquat 

 Diuron 

 Fluridone 
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 Imazapic 

 Overdrive (diflufenzopyr and dicamba) 

 Sulfometuron methyl 

 Tebuthiuron 

 Pesticide degradates and adjuvants (Appendix D – Evaluation of risks from degradates, 

polyoxyethylene-amine (POEA) and R-11, and endocrine disrupting chemicals) 

7.2.3 Assumptions for ecological risk assessments 

There are a number of assumptions involved with the ecological risk assessment process for 

terrestrial and aquatic organisms associated with utilization of the USEPA ’s (2004) process. These 

assumptions may be risk neutral or may lead to an over- or under-estimation of risk from pesticide 

exposure depending upon site-specific conditions. The following describes these assumptions, their 

application to the conditions typically encountered, and whether or not they may lead to 

recommendations that are risk neutral, underestimate, or overestimate ecological risk from potential 

pesticide exposure. 

 Indirect effects would not be evaluated by ecological risk assessments. These effects include the 

mechanisms of indirect exposure to pesticides: consuming prey items (fish, birds, or small 

mammals), reductions in the availability of prey items, and disturbance associated with pesticide 

application activities. 

 Exposure to a pesticide product can be assessed based upon the active ingredient. However, 

exposure to a chemical mixture (pesticide formulation) may result in effects that are similar or 

substantially different compared to only the active ingredient. Nontarget organisms may be 

exposed directly to the pesticide formulation or only various constituents of the formulation as 

they dissipate and partition in the environment. If toxicological information for both the active 

ingredient and formulated product are available, then data representing the greatest potential 

toxicity would be selected for use in the risk assessment process (USEPA 2004). As a result, 

this conservative approach may lead to an overestimation of risk characterization from pesticide 

exposure. 

 Because toxicity tests with listed or candidate species or closely related species are not available, 

data for surrogate species would be most often used for risk assessments. Specifically, bobwhite 

quail and mallard duck are the most frequently used surrogates for evaluating potential toxicity to 

federally listed avian species. Bluegill sunfish, rainbow trout, and fathead minnow are the most 

common surrogates for evaluating toxicity for freshwater fishes. However, sheep’s head minnow 

can be an appropriate surrogate marine species for coastal environments. Rats and mice are the 

most common surrogates for evaluating toxicity for mammals. Interspecies sensitivity is a major 

source of uncertainty in pesticide assessments. As a result of this uncertainty, data is selected for 

the most sensitive species tested within a taxonomic group (birds, fish, and mammals) given the 

quality of the data is acceptable. If additional toxicity data for more species of organisms in a 

particular group are available, the selected data will not be limited to the species previously listed 

as common surrogates. 

 The Kanaga nomogram outputs maximum EEC values that may be used to calculate an average 

daily concentration over a specified interval of time, which is referred to as a time-weightedaverage (TWA). The maximum EEC would be selected as the exposure input for both acute and 

chronic risk assessments in the screening-level evaluations. The initial or maximum EEC 

derived from the Kanaga nomogram represents the maximum expected instantaneous or acute 

exposure to a pesticide. Acute toxicity endpoints are determined using a single exposure to a 

known pesticide concentration typically for 48 to 96 hours. This value is assumed to represent 
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Appendix E: Integrated Pest Management Program E-25 

ecological risk from acute exposure to a pesticide. On the other hand, chronic risk to pesticide 

exposure is a function of pesticide concentration and duration of exposure to the pesticide. An 

organism’s response to chronic pesticide exposure may result from either the concentration of the 

pesticide, length of exposure, or some combination of both factors. Standardized tests for 

chronic toxicity typically involve exposing an organism to several different pesticide 

concentrations for a specified length of time (days, weeks, months, years or generations). For 

example, avian reproduction tests include a 10-week exposure phase. Because a single length of 

time is used in the test, time response data is usually not available for inclusion into risk 

assessments. Without time response data it is difficult to determine the concentration which 

elicited a toxicological response. 

 Using maximum EECs for chronic risk estimates may result in an overestimate of risk, 

particularly for compounds that dissipate rapidly. Conversely, using TWAs for chronic risk 

estimates may underestimate risk if it is the concentration rather than the duration of exposure 

that is primarily responsible for the observed adverse effect. The maximum EEC would be used 

for chronic risk assessments although it may result in an overestimate of risk. TWAs may be 

used for chronic risk assessments, but they will be applied judiciously considering the potential 

for an underestimate or overestimate of risk. For example, the number of days exposure exceeds 

a Level of Concern may influence the suitability of a pesticide use. The greater the number of 

days the EEC exceeds the Level of Concern translates into greater the ecological risk. This is a 

qualitative assessment, and is subject to reviewer’s expertise in ecological risk assessment and 

tolerance for risk. 

 The length of time used to calculate the TWA can have a substantial effect on the exposure 

estimates and there is no standard method for determining the appropriate duration for this 

estimate. The T-REX model assumes a 21-week exposure period, which is equivalent to avian 

reproductive studies designed to establish a steady-state concentration for bioaccumulative 

compounds. However, this does not necessarily define the true exposure duration needed to elicit 

a toxicological response. Pesticides, which do not bioaccumulate, may achieve a steady-state 

concentration earlier than 21 weeks. The duration of time for calculating TWAs will require 

justification and it will not exceed the duration of exposure in the chronic toxicity test 

(approximately 70 days for the standard avian reproduction study). An alternative to using the 

duration of the chronic toxicity study is to base the TWA on the application interval. In this case, 

increasing the application interval would suppress both the estimated peak pesticide 

concentration and the TWA. Another alternative to using TWAs would be to consider the 

number of days that a chemical is predicted to exceed the LOC. 

 Pesticide dissipation is assumed to be first-order in the absence of data suggesting alternative 

dissipation patterns such as bi-phasic. Field dissipation data would generally be the most 

pertinent for assessing exposure in terrestrial species that forage on vegetation. However, this 

data is often not available and it can be misleading particularly if the compound is prone to 

“wash-off”. Soil half-life is the most common degradation data available. Dissipation or 

degradation data that would reflect the environmental conditions typical of Refuge lands would 

be utilized, if available. 

 For species found in the water column, it would be assumed that the greatest bioavailable fraction 

of the pesticide active ingredient in surface waters is freely dissolved in the water column. 

 Actual habitat requirements of any particular terrestrial species are not considered, and it is 

assumed that species exclusively and permanently occupy the treated area, or adjacent areas 

receiving pesticide at rates commensurate with the treatment rate. This assumption would 

produce a maximum estimate of exposure for risk characterization. This assumption would 
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E-26 Appendix E: Integrated Pest Management Program 

likely lead to an overestimation of exposure for species that do not permanently and exclusively 

occupy the treated area (USEPA 2004). 

 Exposure through incidental ingestion of pesticide contaminated soil is not considered in the 

USEPA risk assessment protocols. Research suggests <15% of the diet can consist of 

incidentally ingested soil depending upon species and feeding strategy (Beyer et al. 1994). An 

assessment of pesticide concentrations in soil compared to food item categories in the Kanaga 

nomogram indicates incidental soil ingestion will not likely increase dietary exposure to 

pesticides. Inclusion of soil into the diet would effectively reduce the overall dietary 

concentration compared to the present assumption that the entire diet consists a contaminated 

food source (Fletcher et al. 1994). An exception to this may be soil-applied pesticides in which 

exposure from incidental ingestion of soil may increase. Potential for pesticide exposure under 

this assumption may be underestimated for soil-applied pesticides and overestimated for foliarapplied pesticides. The concentration of a pesticide in soil would likely be less than predicted on 

food items. 

 Exposure through inhalation of pesticides is not considered in the USEPA risk assessment 

protocols. Such exposure may occur through three potential sources: spray material in droplet 

form at time of application, vapor phase with the pesticide volatilizing from treated surfaces, and 

airborne particulates (soil, vegetative matter, and pesticide dusts). The USEPA (1990) reported 

exposure from inhaling spray droplets at the time of application is not an appreciable route of 

exposure for birds. According to research on mallards and bobwhite quail, respirable particle size 

(particles reaching the lung) in birds is limited to maximum diameter of 2 to 5 microns. The 

spray droplet spectra covering the majority of pesticide application scenarios indicate that less 

than 1% of the applied material is within the respirable particle size. This route of exposure is 

further limited because the permissible spray drop size distribution for ground pesticide 

applications is restricted to ASAE medium or coarser drop size distribution. 

 Inhalation of a pesticide in the vapor phase may be another source of exposure for some 

pesticides under certain conditions. This mechanism of exposure to pesticides occurs post 

application and it would pertain to those pesticides with a high vapor pressure. The USEPA is 

currently evaluating protocols for modeling inhalation exposure from pesticides including nearfield and near-ground air concentrations based upon equilibrium and kinetics-based models. Risk 

characterization for exposure with this mechanism is unavailable. 

 The effect from exposure to dusts contaminated with the pesticide cannot be assessed generically 

as partitioning issues related to application site soils and chemical properties of the applied 

pesticides render the exposure potential from this route highly situation specific. 

 Dermal exposure may occur through three potential sources: direct application of spray to 

terrestrial wildlife in the treated area or within the drift footprint, incidental contact with 

contaminated vegetation, or contact with contaminated water or soil. Interception of spray and 

incidental contact with treated substrates may pose risk to avian wildlife (Driver et al. 1991). 

However, available research related to wildlife dermal contact with pesticides is extremely 

limited, except dermal toxicity values are common for some mammals used as human surrogates 

(rats and mice). The USEPA is currently evaluating protocols for modeling dermal exposure. 

Risk characterization may be underestimated for this route of exposure, particularly with high 

risk pesticides such as some organophosphates or carbamate insecticides. If protocols are 

established by the USEPA for assessing dermal exposure to pesticides, they will be considered 

for incorporation into pesticide assessment protocols. 

 Exposure to a pesticide may occur from consuming surface water, dew or other water on treated 

surfaces. Water soluble pesticides have potential to dissolve in surface runoff and puddles in a 
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Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix E: Integrated Pest Management Program E-27 

treated area may contain pesticide residues. Similarly, pesticides with lower organic carbon 

partitioning characteristics and higher solubility in water have a greater potential to dissolve in 

dew and other water associated with plant surfaces. Estimating the extent to which such 

pesticide loadings to drinking water occurs is complex and would depend upon the partitioning 

characteristics of the active ingredient, soils types in the treatment area, and the meteorology of 

the treatment area. In addition, the use of various water sources by wildlife is highly speciesspecific. Currently, risk characterization for this exposure mechanism is not available. The 

USEPA is actively developing protocols to quantify drinking water exposures from puddles and 

dew. If and when protocols are formally established by the USEPA for assessing exposure to 

pesticides through drinking water, these protocols will be incorporated into pesticide risk 

assessment protocols. 

 Risk assessments are based upon the assumption that the entire treatment area would be subject 

to pesticide application at the rates specified on the label. In most cases, there is potential for 

uneven application of pesticides through such plausible incidents such as changes in calibration 

of application equipment, spillage, and localized releases at specific areas in or near the treated 

field that are associated with mixing and handling and application equipment as well as 

applicator skill. Inappropriate use of pesticides and the occurrence of spills represent a potential 

underestimate of risk. It is likely not an important factor for risk characterization. All pesticide 

applicators are required to be certified by the State in which they apply pesticides. Certification 

training includes the safe storage, transport, handling, and mixing of pesticides, equipment 

calibration and proper application with annual continuing education. 

 The USEPA relies on Fletcher (1994) for setting the assumed pesticide residues in wildlife 

dietary items. The USEPA (2004) “believes that these residue assumptions reflect a realistic 

upper-bound residue estimate, although the degree to which this assumption reflects a specific 

percentile estimate is difficult to quantify”. Fletcher’s (1994) research suggests that the pesticide 

active ingredient residue assumptions used by the USEPA represent a 95th percentile estimate. 

However, research conducted by Pfleeger et al. (1996) indicates USEPA residue assumptions for 

short grass was not exceeded. Baehr and Habig (2000) compared USEPA residue assumptions 

with distributions of measured pesticide residues for the USEPA’s UTAB database. Overall 

residue selection level will tend to overestimate risk characterization. This is particularly evident 

when wildlife individuals are likely to have selected a variety of food items acquired from 

multiple locations. Some food items may be contaminated with pesticide residues whereas others 

are not contaminated. However, it is important to recognize differences in species feeding 

behavior. Some species may consume whole above-ground plant material, but others will 

preferentially select different plant structures. Also, species may preferentially select a food item 

although multiple food items may be present. Without species specific knowledge regarding 

foraging behavior characterizing ecological risk other than in general terms is not possible. 

 Acute and chronic risk assessments rely on comparisons of wildlife dietary residues with LC50 or 

NOEC values expressed as concentrations of pesticides in laboratory feed. These comparisons 

assume that ingestion of food items in the field occurs at rates commensurate with those in the 

laboratory. Although the screening assessment process adjusts dry-weight estimates of food 

intake to reflect the increased mass in fresh-weight wildlife food intake estimates, it does not 

allow for gross energy and assimilative efficiency differences between wildlife food items and 

laboratory feed. Differences in assimilative efficiency between laboratory and wild diets suggest 

that current screening assessment methods are not accounting for a potentially important aspect 

of food requirements. 
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E-28 Appendix E: Integrated Pest Management Program 

 There are several other assumptions that can affect nontarget species not considered in the risk 

assessment process. These include possible additive or synergistic effects from applying two or 

more pesticides or additives in a single application, co-location of pesticides in the environment, 

cumulative effects from pesticides with the same mode of action, effects of multiple stressors 

(e.g., combination of pesticide exposure, adverse abiotic and biotic factors) and behavioral 

changes induced by exposure to a pesticide. These factors may exist at some level contributing 

to adverse affects to nontarget species, but they are usually characterized in the published 

literature in only a general manner limiting their value in the risk assessment process.

 It is assumed that aquatic species exclusively and permanently occupy the water body being 

assessed. Actual habitat requirements of aquatic species are not considered. With the possible 

exception of scenarios where pesticides are directly applied to water, it is assumed that no habitat 

use considerations specific for any species would place the organisms in closer proximity to 

pesticide use sites. This assumption produces a maximum estimate of exposure or risk 

characterization. It would likely be realistic for many aquatic species that may be found in 

aquatic habitats within or in close proximity to treated terrestrial habitats. However, the spatial 

distribution of wildlife is usually not random because wildlife distributions are often related to 

habitat requirements of species. Clumped distributions of wildlife may result in an under- or 

over-estimation of risk depending upon where the initial pesticide concentration occurs relative 

to the species or species habitat. 

 For species found in the water column, it would be assumed that the greatest bioavailable fraction 

of the pesticide active ingredient in surface waters is freely dissolved in the water column. 

Additional chemical exposure from materials associated with suspended solids or food items is 

not considered because partitioning onto sediments likely is minimal. Adsorption and 

bioconcentration occurs at lower levels for many newer pesticides compared with older more 

persistent bioaccumulative compounds. Pesticides with RQs close to the listed species level of 

concern, the potential for additional exposure from these routes may be a limitation of risk 

assessments, where potential pesticide exposure or risk may be underestimated. 

 Mass transport losses of pesticide from a water body (except for losses by volatilization, 

degradation and sediment partitioning) would not be considered for ecological risk assessment. 

The water body would be assumed to capture all pesticide active ingredients entering as runoff, 

drift, and adsorbed to eroded soil particles. It would also be assumed that pesticide active 

ingredient is not lost from the water body by overtopping or flow-through, nor is concentration 

reduced by dilution. In total, these assumptions would lead to a near maximum possible waterborne concentration. However, this assumption would not account for potential to concentrate 

pesticide through the evaporative loss. This limitation may have the greatest impact on water 

bodies with high surface-to-volume ratios such as ephemeral wetlands, where evaporative losses 

are accentuated and applied pesticides have low rates of degradation and volatilization. 

 For acute risk assessments, there would be no averaging time for exposure. An instantaneous 

peak concentration would be assumed, where instantaneous exposure is sufficient in duration to 

elicit acute effects comparable to those observed over more protracted exposure periods 

(typically 48 to 96 hours) tested in the laboratory. In the absence of data regarding time-to-toxic 

event, analyses and latent responses to instantaneous exposure, risk would likely be 

overestimated. 

 For chronic exposure risk assessments, the averaging times considered for exposure are 

commensurate with the duration of invertebrate life-cycle or fish-early life stage tests (e.g., 21-28 

days and 56-60 days, respectively). Response profiles (time to effect and latency of effect) to 

pesticides likely vary widely with mode of action and species and should be evaluated on a case-
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Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix E: Integrated Pest Management Program E-29 

by-case basis as available data allow. Nevertheless, because the USEPA relies on chronic 

exposure toxicity endpoints based on a finding of no observed effect, the potential for any latent 

toxicity effects or averaging time assumptions to alter the results of an acceptable chronic risk 

assessment prediction is limited. The extent to which duration of exposure from water-borne 

concentrations overestimate or underestimate actual exposure depends on several factors. These 

include the following: localized meteorological conditions, runoff characteristics of the 

watershed (e.g., soils, topography), the hydrological characteristics of receiving waters, 

environmental fate of the pesticide active ingredient, and the method of pesticide application. It 

should also be understood that chronic effects studies are performed using a method that holds 

water concentration in a steady state. This method is not likely to reflect conditions associated 

with pesticide runoff. Pesticide concentrations in the field increase and decrease in surface water 

on a cycle influenced by rainfall, pesticide use patterns, and degradation rates. As a result of the 

dependency of this assumption on several undefined variables, risk associated with chronic 

exposure may in some situations underestimate risk and overestimate risk in others. 

 There are several other factors that can affect nontarget species not considered in the risk 

assessment process. These would include the following: possible additive or synergistic effects 

from applying two or more pesticides or additives in a single application, co-location of 

pesticides in the environment, cumulative effects from pesticides with the same mode of action, 

effects of multiple stressors (e.g., combination of pesticide exposure, adverse abiotic [not 

pesticides] and biotic factors), and sub-lethal effects such as behavioral changes induced by 

exposure to a pesticide. These factors may exist at some level contributing to adverse affects to 

nontarget species, but they are not routinely assessed by regulatory agencies. Therefore, 

information on the factors is not extensive limiting their value for the risk assessment process. As 

this type of information becomes available, it would be included, either quantitatively or 

qualitatively, in this risk assessment process. 

 USEPA is required by the Food Quality Protection Act to assess the cumulative risks of 

pesticides that share common mechanisms of toxicity, or act the same within an organism. 

Currently, USEPA has identified four groups of pesticides that have a common mechanism of 

toxicity requiring cumulative risk assessments. These four groups are: the organophosphate 

insecticides, N-methyl carbamate insecticides, triazine herbicides, and chloroacetanilide 

herbicides. 

7.3 Pesticide Mixtures and Degradates 

Pesticide products are usually a formulation of several components generally categorized as active 

ingredients and inert or other ingredients. The term active ingredient is defined by the FIFRA as 

preventing, destroying, repelling, or mitigating the effects of a pest, or it is a plant regulator, 

defoliant, desiccant, or nitrogen stabilizer. In accordance with FIFRA, the active ingredient(s) must 

be identified by name(s) on the pesticide label along with its relative composition expressed in 

percentage(s) by weight. In contrast, inert ingredient(s) are not intended to affect a target pest. Their 

role in the pesticide formulation is to act as a solvent (keep the active ingredient is a liquid phase), an 

emulsifying or suspending agent (keep the active ingredient from separating out of solution), or a 

carrier such as clay in which the active ingredient is impregnated on the clay particle in dry 

formulations. For example, if isopropyl alcohol would be used as a solvent in a pesticide 

formulation, then it would be considered an inert ingredient. FIFRA only requires that inert 

ingredients identified as hazardous and associated percent composition, and the total percentage of 

all inert ingredients must be declared on a product label. Inert ingredients that are not classified as 

hazardous are not required to be identified. 
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E-30 Appendix E: Integrated Pest Management Program 

The USEPA (September 1997) issued Pesticide Regulation Notice 97-6 which encouraged 

manufacturers, formulators, producers, and registrants of pesticide products to voluntarily substitute 

the term “other ingredients” for “inert ingredients” in the ingredient statement. This change 

recognized that all components in a pesticide formulation potentially could elicit or contribute to an 

adverse effect on nontarget organisms and, therefore, are not necessarily inert. Whether referred to 

as “inerts” or “other ingredients,” these constituents within a pesticide product have the potential to 

affect species or environmental quality. The USEPA categorizes regulated inert ingredients into the 

following four lists (http://www.epa.gov/opprd001/inerts/index.html): 

• List 1 – Inert Ingredients of Toxicological Concern 

• List 2 – Potentially Toxic Inert Ingredients 

• List 3 – Inerts of Unknown Toxicity 

• List 4 – Inerts of Minimal Toxicity 

Several of the List 4 compounds are naturally-occurring earthen materials (e.g., clay materials, 

simple salts) that would not elicit toxicological response at applied concentrations. However, some 

of the inerts (particularly the List 3 compounds and unlisted compounds) may have moderate to high 

potential toxicity to aquatic species based on MSDSs or published data. 

Comprehensively assessing potential effects to nontarget fish, wildlife, plants, and/or their habitats 

from pesticide use is a complex task. It would be preferable to assess the cumulative effects from 

exposure to the active ingredient, its degradates, and inert ingredients as well as other active 

ingredients in the spray mixture. However, it would only be feasible to conduct deterministic risk 

assessments for each component in the spray mixture singly. Limited scientific information is 

available regarding ecological effects (additive or synergistic) from chemical mixtures that typically 

rely upon broadly encompassing assumptions. For example, the US Forest Service (2005) found that 

mixtures of pesticides used in land (forest) management likely would not cause additive or 

synergistic effects to nontarget species based upon a review of scientific literature regarding 

toxicological effects and interactions of agricultural chemicals (ATSDR 2004). Moreover, 

information on inert ingredients, adjuvants, and degradates is often limited by the availability of and 

access to reliable toxicological data for these constituents. 

Toxicological information regarding “other ingredients” may be available from sources such as the 

following: 

• TOMES (a proprietary toxicological database including USEPA’s IRIS, the Hazardous Substance 

Data Bank, the Registry of Toxic Effects of Chemical Substances [RTECS]). 

• USEPA’s ECOTOX database, which includes AQUIRE (a database containing scientific papers 

published on the toxic effects of chemicals to aquatic organisms). 

• TOXLINE (a literature searching tool). 

• Material Safety Data Sheets (MSDSs) from pesticide suppliers. 

• Other sources such as the Farm Chemicals Handbook. 

Because there is a lack of specific inert toxicological data, inert(s) in a pesticide may cause adverse 

ecological effects. However, inert ingredients typically represent only a small percentage of the 

pesticide spray mixture, and it would be assumed that negligible effects would be expected to result 

from inert ingredient(s). 

Although the potential effects of degradates should be considered when selecting a pesticide, it is 

beyond the scope of this assessment process to consider all possible breakdown chemicals of the 
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Appendix E: Integrated Pest Management Program E-31 

various product formulations containing an active ingredient. Degradates may be more or less 

mobile and more or less hazardous in the environment than their parent pesticides (Battaglin et al. 

2003). Differences in environmental behavior (e.g., mobility) and toxicity between parent pesticides 

and degradates would make assessing potential degradate effects extremely difficult. For example, a 

less toxic and more mobile, bioaccumulative, or persistent degradate may have potentially greater 

effects on species and/or degrade environmental quality. The lack of data on the toxicity of 

degradates for many pesticides would represent a source of uncertainty for assessing risk. 

An USEPA-approved label specifies whether a product can be mixed with one or more pesticides. 

Without product-specific toxicological data, it would not possible to quantify the potential effects of 

these mixtures. In addition, a quantitative analysis could only be conducted if reliable scientific 

information allowed a determination of whether the joint action of a mixture would be additive, 

synergistic, or antagonistic. Such information would not likely exist unless the mode of action would 

be common among the chemicals and receptors. Moreover, the composition of and exposure to 

mixtures would be highly site- and/or time-specific and, therefore, it would be nearly impossible to 

assess potential effects to species and environmental quality. 

To minimize or eliminate potential negative effects associated with applying two or more pesticides 

as a mixture, the use would be conducted in accordance with the labeling requirements. Labels for 

two or more pesticides applied as a mixture should be completely reviewed, where products with the 

least potential for negative effects would be selected for use on the Refuge. This is especially 

relevant when a mixture would be applied in a manner that may already have the potential for an 

effect(s) associated with an individual pesticide (e.g., runoff to ponds in sandy watersheds). Use of a 

tank mix under these conditions would increase the level of uncertainty in terms of risk to species or 

potential to degrade environmental quality. 

Adjuvants generally function to enhance or prolong the activity of pesticide. For terrestrial 

herbicides, adjuvants aid in the absorption into plant tissue. Adjuvant is a broad term that generally 

applies to surfactants, selected oils, anti-foaming agents, buffering compounds, drift control agents, 

compatibility agents, stickers, and spreaders. Adjuvants are not under the same registration 

requirements as pesticides and the USEPA does not register or approve the labeling of spray 

adjuvants. Individual pesticide labels identify types of adjuvants approved for use with it. In 

general, adjuvants compose a relatively small portion of the volume of pesticides applied. Selection 

of adjuvants with limited toxicity and low volumes would be recommended to reduce the potential 

for the adjuvant to influence the toxicity of the pesticide. 

7.4 Determining Effects to Soil and Water Quality 

The approval process for pesticide uses would consider potential to degrade water quality on and off 

Refuge lands. A pesticide can only affect water quality through movement away from the treatment 

site. After application, pesticide mobilization can be characterized by one or more of the following 

(Kerle et al. 1996): 

 Attach (sorb) to soil, vegetation, or other surfaces and remain at or near the treated area; 

 Attach to soil and move off-site through erosion from run-off or wind; 

 Dissolve in water that can be subjected to run-off or leaching. 
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E-32 Appendix E: Integrated Pest Management Program 

As an initial screening tool, selected chemical characteristics and rating criteria for a pesticide can be 

evaluated to assess potential to enter ground and/or surface waters. These would include the 

following: persistence, sorption coefficient (Koc), groundwater ubiquity score (GUS), and solubility. 

Persistence, which is expressed as half-life (t1⁄2), represents the length of time required for 50% of the 

deposited pesticide to degrade (completely or partially). Persistence in the soil can be categorized as 

the following: nonpersistent <30 days, moderately persistent = 30 to 100 days, and persistent >100 

days (Kerle et. al. 1996). Half-life data is usually available for aquatic and terrestrial environments. 

Another measure of pesticide persistence is dissipation time (DT50). It represents the time required 

for 50% of the deposited pesticide to degrade and move from a treated site; whereas, half-life 

describes the rate for degradation only. As for half-life, units of dissipation time are usually 

expressed in days. Field or foliar dissipation time is the preferred data for use to estimate pesticide 

concentrations in the environment. However, soil half-life is the most common persistence data 

cited in published literature. If field or foliar dissipation data is not available, soil half-life data may 

be used. The average or representative half-life value of most important degradation mechanism will 

be selected for quantitative analysis for both terrestrial and aquatic environments. 

Mobility of a pesticide is a function of how strongly it is adsorbed to soil particles and organic 

matter, its solubility in water, and its persistence in the environment. Pesticides strongly adsorbed to 

soil particles, relatively insoluble in water, and not environmentally persistent would be less likely to 

move across the soil surface into surface waters or to leach through the soil profile and contaminate 

groundwater. Conversely, pesticides that are not strongly adsorbed to soil particles, are highly water 

soluble, and are persistent in the environment would have greater potential to move from the 

application site (off-site movement). 

The degree of pesticide adsorption to soil particles and organic matter (Kerle et. al. 1996) is 

expressed as the soil adsorption coefficient (Koc). The soil adsorption coefficient is measured as 

micrograms of pesticide per gram of soil (μg/g) that can range from near zero to the thousands. 

Pesticides with higher Koc values are strongly sorbed to soil and, therefore, would be less subject to 

movement. 

Water solubility describes the amount of pesticide that will dissolve in a known quantity of water. 

The water solubility of a pesticide is expressed as milligrams of pesticide dissolved in a liter of water 

(mg/l or ppm). Pesticide with solubility <0.1 ppm are virtually insoluble in water, 100-1000 ppm are 

moderately soluble, and >10,000 ppm highly soluble (US Geological Survey 2000). As pesticide 

solubility increases, there would be greater potential for off-site movement. 

The Groundwater Ubiquity Score (GUS) is a quantitative screening tool to estimate a pesticide’s 

potential to move in the environment. It utilizes soil persistence and adsorption coefficients in the 

following formula. 

GUS = log10 (t1⁄2) x [4 - log10 (Koc)] 

The potential pesticide movement rating would be based upon its GUS value. Pesticides with a GUS 

<0.1 would considered to have an extremely low potential to move toward groundwater. Values of 

1.0-2.0 would be low, 2.0-3.0 would be moderate, 3.0-4.0 would be high, and 

>4.0 would have a very high potential to move toward groundwater. 
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Appendix E: Integrated Pest Management Program E-33 

Water solubility describes the amount of pesticide dissolving in a specific quantity of water, where it 

is usually measured as mg/l or parts per million (ppm). Solubility is useful as a comparative measure 

because pesticides with higher values are more likely to move by run-off or leaching. GUS, water 

solubility, t1⁄2, and Koc values are available for selected pesticides from the OSU Extension Pesticide 

Properties Database at http://npic.orst.edu/ppdmove.htm. Many of the values in this database were 

derived from the SCS/ARS/CES Pesticide Properties Database for Environmental Decision Making 

(Wauchope et al. 1992). 

Soil properties influence the fate of pesticides in the environment. The following six properties are 

mostly likely to affect pesticide degradation and the potential for pesticides to move off-site by 

leaching (vertical movement through the soil) or runoff (lateral movement across the soil surface). 

 Permeability is the rate of water movement vertically through the soil. It is affected by soil 

texture and structure. Coarse textured soils (e.g., high sand content) have a larger pore size and 

they are generally more permeable than fine textured soils (i.e., high clay content). The more 

permeable soils would have a greater potential for pesticides to move vertically down through the 

soil profile. Soil permeability rates (inches/hour) are usually available in county soil survey 

reports. 

 Soil texture describes the relative percentage of sand, silt, and clay. In general, greater clay 

content with smaller the pore size would lower the likelihood and rate water that would move 

through the soil profile. Clay also serves to adsorb (bind) pesticides to soil particles. Soils with 

high clay content would adsorb more pesticide than soils with relatively low clay content. In 

contrast, sandy soils with coarser texture and lower water holding capacity would have a greater 

potential for water to leach through them. 

 Soil structure describes soil aggregation. Soils with a well developed soil structure have looser, 

more aggregated, structure that would be less likely to be compacted. Both characteristics would 

allow for less restricted flow of water through the soil profile resulting in greater infiltration.

 Organic matter would be the single most important factor affecting pesticide adsorption in soils. 

Many pesticides are adsorbed to organic matter which would reduce their rate of downward 

movement through the soil profile. Also, soils high in organic matter would tend to hold more 

water, which may make less water available for leaching. 

 Soil moisture affects how fast water would move through the soil. If soils are already wet or 

saturated before rainfall or irrigation, excess moisture would runoff rather than infiltrate into the 

soil profile. Soil moisture also would influence microbial and chemical activity in soil, which 

effects pesticide degradation. 

 Soil pH would influence chemical reactions that occur in the soil which in turn determines 

whether or not a pesticide will degrade, rate of degradation, and, in some instances, which 

degradation products are produced. 

Based upon the aforementioned properties, soils most vulnerable to groundwater contamination 

would be sandy soils with low organic matter. In contrast, the least vulnerable soils would be welldrained clayey soils with high organic matter. Consequently, pesticides with the lowest potential for 

movement in conjunction with appropriate best management practices (see below) would be used in 

an IPM framework to treat pests while minimizing effects to nontarget biota and protecting 

environmental quality. 
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Along with soil properties, the potential for a pesticide to affect water quality through run-off and 

leaching would consider site-specific environmental and abiotic conditions including rainfall, water 

table conditions, and topography (Huddleston 1996). 

 Water is necessary to separate pesticides from soil. This can occur in two basic ways. Pesticides 

that are soluble move easily with runoff water. Pesticide-laden soil particles can be dislodged 

and transported from the application site in runoff. The concentration of pesticides in the surface 

runoff would be greatest for the first runoff event following treatment. The rainfall intensity and 

route of water infiltration into soil, to a large extent, determine pesticide concentrations and 

losses in surface runoff. The timing of the rainfall after application also would have an effect. 

Rainfall interacts with pesticides at a shallow soil depth (1⁄4 to 1⁄2 inch), which is called the mixing 

zone (Baker and Miller 1999). The pesticide/water mixture in the mixing zone would tend to 

leach down into the soil or runoff depending upon how quickly the soil surface becomes 

saturated and how rapidly water can infiltrate into the soil. Leaching would decrease the amount 

of pesticide available near the soil surface (mixing zone) to runoff during the initial rainfall event 

following application and subsequent rainfall events. 

 Terrain slope would affect the potential for surface runoff and the intensity of runoff. Steeper 

slopes would have greater potential for runoff following a rainfall event. In contrast, soils that 

are relatively flat would have little potential for runoff, except during intense rainfall events. In 

addition, soils in lower areas would be more susceptible to leaching as a result of receiving 

excessive water from surrounding higher elevations. 

 Depth to groundwater would be an important factor affecting the potential for pesticides to leach 

into groundwater. If the distance from the soil surface to the top of the water table is shallow, 

pesticides would have less distance to travel to reach groundwater. Shallower water tables that 

persist for longer periods would be more likely to experience groundwater contamination. Soil 

survey reports are available for individual counties. These reports provide data in tabular format 

regarding the water table depths and the months during which it is persists. In some situations, a 

hard pan exists above the water table that would prevent pesticide contamination from leaching. 

7.5 Determining Effects to Air Quality 

Pesticides may volatilize from soil and plant surfaces and move from the treated area into the 

atmosphere. The potential for a pesticide to volatilize is determined by the pesticide’s vapor pressure 

which would be affected by temperature, sorption, soil moisture, and the pesticide’s water solubility. 

Vapor pressure is often expressed in mm Hg. To make these numbers easier to compare, vapor 

pressure may be expressed in exponent form (I x 10-7), where I represents a vapor pressure index. In 

general, pesticides with I<10 would have a low potential to volatilize; whereas, pesticides with 

I>1,000 would have a high potential to volatilize (Oregon State University 1996). Vapor pressure 

values for pesticides are usually available in the pesticide product MSDS or the USDA Agricultural 

Research Service (ARS) pesticide database. 

7.6 Preparing a Chemical Profile 

The following instructions would be used by Service personnel to complete Chemical Profiles for 

pesticides. Specifically, profiles would be prepared for pesticide active ingredients (e.g., glyphosate, 

imazapic) that would be contained in one or more trade name products that are registered and labeled 

with USEPA. All information fields under each category (e.g., Toxicological Endpoints, 

Environmental Fate) would be completed for a Chemical Profile. If no information is available for a 

specific field, then “No data is available in references” would be recorded in the profile. Available 
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Appendix E: Integrated Pest Management Program E-35 

scientific information would be used to complete Chemical Profiles. Each entry of scientific 

information would be shown with applicable references. 

Completed Chemical Profiles would provide a structured decision-making process utilizing 

quantitative assessment/screening tools with threshold values (where appropriate) that would be used 

to evaluate potential biological and other environmental effects to Refuge resources. For ecological 

risk assessments presented in these profiles, the “worst-case scenario” would be evaluated to 

determine whether a pesticide could be approved for use considering the maximum single application 

rate specified on pesticide labels for habitat management and croplands/facilities maintenance 

treatments pertaining to Refuges. Where the “worst-case scenario” likely would only result in minor, 

temporary, and localized effects to listed and nonlisted species with appropriate BMPs (see Section 

5.0), the proposed pesticide’s use in a PUP would have a scientific basis for approval under any 

application rate specified on the label that is at or below rates evaluated in a Chemical Profile. In 

some cases, the Chemical Profile would include a lower application rate than the maximum labeled 

rate in order to protect Refuge resources. As necessary, Chemical Profiles would be periodically 

updated with new scientific information or as pesticides with the same active ingredient are proposed 

for use on the Refuge in PUPs. 

Throughout this section, threshold values (to prevent or minimize potential biological and 

environmental effects) would be clearly identified for specific information presented in a completed 

Chemical Profile. Comparison with these threshold values provides an explicit scientific basis to 

approve or disapprove PUPs for habitat management and cropland/facilities maintenance on Refuge 

lands. In general, PUPs would be approved for pesticides with Chemical Profiles where there would 

be no exceedances of threshold values. However, BMPs are identified for some screening tools that 

would minimize/eliminate potential effects (exceedance of the threshold value) as a basis for 

approving PUPs. 

Date: Service personnel would record the date when the Chemical Profile is completed or updated. 

Chemical Profiles (e.g., currently approved pesticide use patterns) would be periodically reviewed 

and updated, as necessary. The most recent review date would be recorded on a profile to document 

when it was last updated. 

Trade Name(s): Service personnel would accurately and completely record the trade name(s) from 

the pesticide label, which includes a suffix that describes the formulation (e.g., WP, DG, EC, L, SP, 

I, II or 64). The suffix often distinguishes a specific product among several pesticides with the same 

active ingredient. Service personnel would record a trade name for each pesticide product with the 

same active ingredient. 

Common chemical name(s): Service personnel would record the common name(s) listed on the 

pesticide label or material safety data sheet (MSDS) for an active ingredient. The common name of a 

pesticide is listed as the active ingredient on the title page of the product label immediately following 

the trade name, and the MSDS, Section 2: Composition/ Information on Ingredients. A Chemical 

Profile is completed for each active ingredient. 

Pesticide Type: Service personnel would record the type of pesticide for an active ingredient as one 

of the following: herbicide, dessicant, fungicide, fumigant, growth regulator, insecticide, pisicide, or 

rodenticide. 
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EPA Registration Number(s): This number (EPA Reg. No.) appears on the title page of the label 

and MSDS, Section 1: Chemical Product and Company Description. It is not the EPA 

Establishment Number that is usually located near it. Service personnel would record the EPA Reg. 

No. for each trade name product with an active ingredient based upon PUPs. 

Pesticide Class: Service personnel would list the general chemical class for the pesticide (active 

ingredient). For example, malathion is an organophosphate and carbaryl is a carbamate. 

CAS (Chemical Abstract Service) Number: This number is often located in the second section 

(Composition/Information on Ingredients) of the MSDS. The MSDS table listing components 

usually contains this number immediately prior to or following the % composition. 

Other Ingredients: From the most recent MSDS for the proposed pesticide product(s), Service 

personnel would include any chemicals in the pesticide formulation not listed as an active ingredient 

that are described as toxic or hazardous, or regulated under the Superfund Amendments and 

Reauthorization Act (SARA), Comprehensive Environmental Response, Compensation, and Liability 

Act (CERCLA), Toxic Substances Control Act (TSCA), Occupational Safety and Health 

Administration (OSHA), State Right-to-Know, or other listed authorities. These are usually found in 

MSDS sections titled “Hazardous Identifications”, “Exposure Control/Personal Protection”, and 

“Regulatory Information”. If concentrations of other ingredients are available for any compounds 

identified as toxic or hazardous, then Service personnel would record this information in the 

Chemical Profile by trade name. MSDS(s) may be obtained from the manufacturer, manufacturer’s 

website or from an on-line database maintained by Crop Data Management Systems, Inc. (see list 

below). 

Toxicological Endpoints 

Toxicological endpoint data would be collected for acute and chronic tests with mammals, birds, and 

fish. Data would be recorded for species available in the scientific literature. If no data are found for 

a particular taxonomic group, then “No data available is references” would be recorded as the data 

entry. Throughout the Chemical Profile, references (including toxicological endpoint data) would be 

cited using parentheses (#) following the recorded data. 

Mammalian LD50: For test species in the scientific literature, Service personnel would record 

available data for oral lethal dose (LD50) in mg/kg-bw (body weight) or ppm-bw. Most common test 

species in scientific literature are the rat and mouse. The lowest LD50 value found for a rat would be 

used as a toxicological endpoint for dose-based RQ calculations to assess acute risk to mammals (see 

Table 1 in Section 7.1). 

Mammalian LC50: For test species in the scientific literature, Service personnel would record 

available data for dietary lethal concentration (LC50) as reported (e.g., mg/kg-diet or ppm-diet). Most 

common test species in scientific literature are the rat and mouse. The lowest LC50 value found for a 

rat would be used as a toxicological endpoint for diet-based RQ calculations to assess acute risk (see 

Table 1 in Section 7.1). 

Mammalian Reproduction: For test species listed in the scientific literature, Service personnel 

would record the test results (e.g., Lowest Observed Effect Concentration [LOEC], Lowest Observed 

Effect Level [LOEL], No Observed Adverse Effect Level [NOAEL], No Observed Adverse Effect 
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Appendix E: Integrated Pest Management Program E-37 

Concentration [NOAEC]) in mg/kg-bw or mg/kg-diet for reproductive test procedure(s) (e.g., 

generational studies [preferred], fertility, new born weight). Most common test species available in 

scientific literature are rats and mice. The lowest NOEC, NOAEC, NOEL, or NOAEL test results 

found for a rat would be used as a toxicological endpoint for RQ calculations to assess chronic risk 

(see Table 1 in Section 7.1). 

Avian LD50: For test species available in the scientific literature, Service personnel would record 

values for oral lethal dose (LD50) in mg/kg-bw or ppm-bw. Most common test species available in 

scientific literature are the bobwhite quail and mallard. The lowest LD50 value found for an avian 

species would be used as a toxicological endpoint for dose-based RQ calculations to assess acute risk 

(see Table 1 in Section 7.1). 

Avian LC50: For test species available in the scientific literature, Service personnel would record 

values for dietary lethal concentration (LC50) as reported (e.g., mg/kg-diet or ppm-diet). Most 

common test species available in scientific literature are the bobwhite quail and mallard. The lowest 

LC50 value found for an avian species would be used as a toxicological endpoint for dietary-based 

RQ calculations to assess acute risk (see Table 1 in Section 7.1). 

Avian Reproduction: For test species available in the scientific literature, Service personnel would

record test results (e.g., LOEC, LOEL, NOAEC, NOAEL) in mg/kg-bw or mg/kg-diet consumed for 

reproductive test procedure(s) (e.g., early life cycle, reproductive). Most common test species 

available in scientific literature are the bobwhite quail and mallard. The lowest NOEC, NOAEC, 

NOEL, or NOAEL test results found for an avian species would be used as a toxicological endpoint 

for RQ calculations to assess chronic risk (see Table 1 in Section 7.1). 

Fish LC50: For test freshwater or marine species listed in the scientific literature, Service personnel 

would record a LC50 in ppm or mg/L. Most common test species available in the scientific literature 

are the bluegill, rainbow trout, and fathead minnow (marine). Test results for many game species 

may also be available. The lowest LC50 value found for a freshwater fish species would be used as a 

toxicological endpoint for RQ calculations to assess acute risk (see Table 1 in Section 7.1). 

Fish Early Life Stage (ELS)/Life Cycle: For test freshwater or marine species available in the 

scientific literature, Service personnel would record test results (e.g., LOEC, NOAEL, NOAEC, 

LOAEC) in ppm for test procedure(s) (e.g., early life cycle, life cycle). Most common test species 

available in the scientific literature are bluegill, rainbow trout, and fathead minnow. Test results for 

other game species may also be available. The lowest test value found for a fish species (preferably 

freshwater) would be used as a toxicological endpoint for RQ calculations to assess chronic risk (see 

Table 1 in Section 7.1). 

Other: For test invertebrate as well as nonvascular and vascular plant species available in the 

scientific literature, Service personnel would record LC50, LD50, LOEC, LOEL, NOAEC, NOAEL, or 

EC50 (environmental concentration) values in ppm or mg/L. Most common test invertebrate species 

available in scientific literature are the honey bee and the water flea (Daphnia magna). Green algae 

(Selenastrum capricornutum) and pondweed (Lemna minor) are frequently available test species for 

aquatic nonvascular and vascular plants, respectively. 

Ecological Incident Reports: After a site has been treated with pesticide(s), wildlife may be 

exposed to these chemical(s). When exposure is high relative to the toxicity of the pesticides, 

wildlife may be killed or visibly harmed (incapacitated). Such events are called ecological incidents. 
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E-38 Appendix E: Integrated Pest Management Program 

The USEPA maintains a database (Ecological Incident Information System) of ecological incidents. 

This database stores information extracted from incident reports submitted by various Federal and 

State agencies and nongovernment organizations. Information included in an incident report is date 

and location of the incident, type and magnitude of affects observed in various species, use(s) of 

pesticides known or suspected of contributing to the incident, and results of any chemical residue and 

cholinesterase activity analyses conducted during the investigation. 

Incident reports can play an important role in evaluating the effects of pesticides by supplementing 

quantitative risk assessments. All incident reports for pesticide(s) with the active ingredient and 

associated information would be recorded. 

Environmental Fate 

Water Solubility: Service personnel would record values for water solubility (Sw), which describes 

the amount of pesticide that dissolves in a known quantity of water. Sw is expressed as mg/L (ppm). 

Pesticide Sw values would be categorized as one of the following: insoluble <0.1 ppm, moderately 

soluble = 100 to 1000 ppm, highly soluble >10,000 ppm (US Geological Survey 2000). As pesticide 

Sw increases, there would be greater potential to degrade water quality through run-off and leaching. 

Sw would be used to evaluate potential for bioaccumulation in aquatic species [see Octanol-Water 

Partition Coefficient (Kow) below]. 

Soil Mobility: Service personnel would record available values for soil adsorption coefficient (Koc

[μg/g]). It provides a measure of a chemical's mobility and leaching potential in soil. Koc values are 

directly proportional to organic content, clay content, and surface area of the soil. Koc data for a 

pesticide may be available for a variety of soil types (e.g., clay, loam, sand). 

Koc values would be used in evaluating the potential to degrade groundwater by leaching (see

Potential to Move to Groundwater below).

Soil Persistence: Service personnel would record values for soil half-life (t1⁄2), which represents the 

length of time (days) required for 50% of the deposited pesticide to degrade (completely or partially) 

in the soil. Based upon the t1⁄2 value, soil persistence would be categorized as one of the following: 

nonpersistent <30 days, moderately persistent = 30 to 100 days, and persistent >100 days (Kerle et. 

al. 1996). 

Threshold for Approving PUPs: 

If soil t1⁄2 ≤100 days, then a PUP would be approved without additional BMPs to protect water 

quality. 

If soil t1⁄2 >100 days, then a PUP would only be approved with additional BMPs specifically to 

protect water quality. One or more BMPs such as the following would be included in the Specific 

Best Management Practices (BMPs) section to minimize potential surface run-off and leaching 

that can degrade water quality: 

 Do not exceed one application per site per year. 

 Do not use on coarse-textured soils where the ground water table is <10’ and average annual 

precipitation >12”. 
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Appendix E: Integrated Pest Management Program E-39 

 Do not use on steep slopes if substantial rainfall is expected within 24 hours or ground is 

saturated. 

Along with Koc, soil t1⁄2 values would be used in evaluating the potential to degrade groundwater by 

leaching (see Potential to Move to Groundwater below). 

Soil Dissipation: Dissipation time (DT50) represents the time required for 50% of the deposited 

pesticide to degrade and move from a treated site; whereas, soil t1⁄2 describes the rate for degradation 

only. As for t1⁄2, units of dissipation time are usually expressed in days. Field dissipation time would 

be the preferred data for use to estimate pesticide concentrations in the environment because it is 

based upon field studies compared to soil t1⁄2, which is derived in a laboratory. However, soil t1⁄2 is the 

most common persistence data available in the published literature. If field dissipation data is not 

available, soil half-life data would be used in a Chemical Profile. The average or representative halflife value of most important degradation mechanism would be selected for quantitative analysis for 

both terrestrial and aquatic environments. 

Based upon the DT50 value, environmental persistence in the soil also would be categorized as one of 

the following: nonpersistent <30 days, moderately persistent = 30-100 days, and persistent >100 

days. 

Threshold for Approving PUPs: 

If soil DT50 ≤100 days, then a PUP would be approved without additional BMPs to protect water 

quality. 

If soil DT50 >100 days, then a PUP would only be approved with additional BMPs specifically to 

protect water quality. One or more BMPs such as the following would be included in the Specific 

Best Management Practices (BMPs) section to minimize potential surface run-off and leaching that 

can degrade water quality: 

 Do not exceed one application per site per year. 

 Do not use on coarse-textured soils where the ground water table is <10’ and average annual 

precipitation >12”. 

 Do not use on steep slopes if substantial rainfall is expected within 24 hours or ground is 

saturated. 

Along with Koc, soil DT50 values (preferred over soil t1⁄2) would be used in evaluating the potential to 

degrade groundwater by leaching (see Potential to Move to Groundwater below), if available. 

Aquatic Persistence: Service personnel would record values for aquatic t1⁄2, which represents the 

length of time required for 50% of the deposited pesticide to degrade (completely or partially) in 

water. Based upon the t1⁄2 value, aquatic persistence would be categorized as one of the following: 

nonpersistent <30 days, moderately persistent = 30 to 100 days, and 

persistent >100 days (Kerle et. al. 1996). 

Threshold for Approving PUPs: 

If aquatic t1⁄2 ≤100 days, then a PUP would be approved without additional BMPs to protect water 

quality. 
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E-40 Appendix E: Integrated Pest Management Program 

If aquatic t1⁄2 >100 days, then a PUP would only be approved with additional BMPs specifically to 

protect water quality. One or more BMPs such as the following would be included in the Specific 

Best Management Practices (BMPs) section to minimize potential surface run-off and leaching that 

can degrade water quality: 

 Do not exceed one application per site per year. 

 Do not use on coarse-textured soils where the ground water table is <10’ and average annual 

precipitation >12”. 

 Do not use on steep slopes if substantial rainfall is expected within 24 hours or ground is 

saturated. 

Aquatic Dissipation: Dissipation time (DT50) represents the time required for 50% of the deposited 

pesticide to degrade or move (dissipate); whereas, aquatic t1⁄2 describes the rate for degradation only. 

As for t1⁄2, units of dissipation time are usually expressed in days. Based upon the DT50 value, 

environmental persistence in aquatic habitats also would be categorized as one of the following: 

nonpersistent <30 days, moderately persistent = 30 to 100 days, and 

persistent >100 days. 

Threshold for Approving PUPs: 

If aquatic DT50 ≤100 days, then a PUP would be approved without additional BMPs to protect water 

quality. 

If aquatic DT50 >100 days, then a PUP would only be approved with additional BMPs specifically to 

protect water quality. One or more BMPs such as the following would be included in the Specific 

Best Management Practices (BMPs) section to minimize potential surface run-off and leaching that 

can degrade water quality: 

 Do not exceed one application per site per year. 

 Do not use on coarse-textured soils where the ground water table is <10’ and average annual 

precipitation >12”. 

 Do not use on steep slopes if substantial rainfall is expected within 24 hours or ground is 

saturated. 

Potential to Move to Groundwater: Groundwater Ubiquity Score (GUS) = log10(soil t 1⁄2) x [4 – 

log10(Koc)]. If a DT50 value is available, it would be used rather than a t 1⁄2 value to calculate a GUS 

score. Based upon the GUS value, the potential to move toward groundwater would be recorded as 

one of the following categories: extremely low potential<1.0, low - 1.0 to 2.0, moderate - 2.0 to 3.0, 

high - 3.0 to 4.0, or very high>4.0. 

Threshold for Approving PUPs: 

If GUS ≤4.0, then a PUP would be approved without additional BMPs to protect water quality. 

If GUS>4.0, then a PUP would only be approved with additional BMPs specifically to protect water 

quality. One or more BMPs such as the following would be included in the Specific Best 

Management Practices (BMPs) section to minimize potential surface run-off and leaching that can 

degrade water quality: 

 Do not exceed one application per site per year. 

 Do not use on coarse-textured soils where the ground water table is <10’ and average annual 

precipitation >12”. 
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Appendix E: Integrated Pest Management Program E-41 

 Do not use on steep slopes if substantial rainfall is expected within 24 hours or ground is 

saturated. 

Volatilization: Pesticides may volatilize (evaporate) from soil and plant surfaces and move offtarget into the atmosphere. The potential for a pesticide to volatilize is a function of its vapor 

pressure that is affected by temperature, sorption, soil moisture, and the pesticide’s water solubility. 

Vapor pressure is often expressed in mm Hg. To make these values easier to compare, vapor pressure 

would be recorded by Service personnel in exponential form (I x 10-7), where I represents a vapor 

pressure index. In general, pesticides with I<10 would have low potential to volatilize; whereas, 

pesticides with I >1,000 would have a high potential to volatilize (Oregon State University 1996). 

Vapor pressure values for pesticides are usually available in the pesticide product MSDS or the 

USDA Agricultural Research Service (ARS) pesticide database (see References). 

Threshold for Approving PUPs: 

If I ≤1000, then a PUP would be approved without additional BMPs to minimize drift and protect air 

quality. 

If I>1000, then a PUP would only be approved with additional BMPs specifically to minimize drift 

and protect air quality. One or more BMPs such as the following would be included in the Specific 

Best Management Practices (BMPs) section to reduce volatilization and potential to drift and 

degrade air quality: 

 Do not treat when wind velocities are <2 or >10 mph with existing or potential inversion 

conditions. 

 Apply the large-diameter droplets possible for spray treatments. 

 Avoid spraying when air temperatures >85o

F. 

 Use the lowest spray height possible above target canopy. 

 Where identified on the pesticide label, soil incorporate pesticide as soon as possible during or 

after application. 

 

Octanol-Water Partition Coefficient (Kow): The octanol-water partition coefficient (Kow) is the 

concentration of a pesticide in octanol and water at equilibrium at a specific temperature. Because 

octanol is an organic solvent, it is considered a surrogate for natural organic matter. Therefore, Kow

would be used to assess potential for a pesticide to bioaccumulate in tissues of aquatic species (e.g., 

fish). If Kow >1000 or Sw<1 mg/L AND soil t1⁄2>30 days, then there would be high potential for a 

pesticide to bioaccumulate in aquatic species such as fish (US Geological Survey 2000). 

Threshold for Approving PUPs: 

If there is not a high potential for a pesticide to bioaccumulate in aquatic species, then the PUP 

would be approved. 

If there is a high potential to bioaccumulate in aquatic species (Kow>1000 or Sw<1 mg/L AND soil 

t1⁄2>30 days), then the PUP would not approved, except under unusual circumstances where approval 

would only be granted by the Washington Office. 

Bioaccumulation/Bioconcentration: The physiological process where pesticide concentrations in 

tissue would increase in biota because they are taken and stored at a faster rate than they are 

metabolized or excreted. The potential for bioaccumulation would be evaluated through 
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bioaccumulation factors (BAFs) or bioconcentration factors (BCFs). Based upon BAF or BCF 

values, the potential to bioaccumulate would be recorded as one of the following: low – 0 to 300, 

moderate – 300 to 1000, or high >1000 (Calabrese and Baldwin 1993). 

Threshold for Approving PUPs: 

If BAF or BCF≤1000, then a PUP would be approved without additional BMPs. 

If BAF or BCF>1000, then a PUP would not approved, except under unusual circumstances where 

approval would only be granted by the Washington Office. 

Worst-Case Ecological Risk Assessment 

Max Application Rates (acid equivalent): Service personnel would record the highest application 

rate of an active ingredient (ae basis) for habitat management and cropland/facilities maintenance 

treatments in this data field of a Chemical Profile. These rates can be found in Table CP.1 under the 

column heading “Max Product Rate – Single Application (lbs/acre – AI on acid equiv basis)”. This 

table would be prepared for a chemical profile from information specified in labels for trade name 

products identified in PUPs. If these data are not available in pesticide labels, then write “NS” for 

“not specified on label” in this table. 

EECs: An estimated environmental concentration (ECC) represents potential exposure to fish and 

wildlife (birds and mammals) from using a pesticide. EECs would be derived by Service personnel 

using an USEPA screening-level approach (USEPA 2004). For each max application rate [see 

description under Max Application Rates (acid equivalent)], Service personnel would record 2 

EEC values in a Chemical Profile; these would represent the worst-case terrestrial and aquatic 

exposures for habitat management and croplands/facilities maintenance treatments. For terrestrial 

and aquatic EEC calculations, see description for data entry under Presumption of Unacceptable 

Risk/Risk Quotients, which is the next field for a Chemical Profile. 

Presumption of Unacceptable Risk/Risk Quotients: Service personnel would calculate and record 

acute and chronic risk quotients (RQs) for birds, mammals, and fish using the provided tabular 

formats for habitat management and/or cropland/facilities maintenance treatments. RQs recorded in 

a Chemical Profile would represent the worst-case assessment for ecological risk. See Section 7.2 

for discussion regarding the calculations of RQs. 

For aquatic assessments associated with habitat management treatments, RQ calculations would be 

based upon selected acute and chronic toxicological endpoints for fish and the EEC would be derived 

from Urban and Cook (1986) assuming 100% overspray to an entire 1-foot deep water body using 

the max application rate (ae basis [see above]). 

For aquatic assessments associated with cropland/facilities maintenance treatments, RQ calculations 

would be done by Service personnel based upon selected acute and chronic toxicological endpoints 

for fish and an EEC would be derived from the aquatic assessment in AgDRIFT® model version 2.01 

under Tier I ground-based application with the following input variables: max application rate (acid 

basis [see above]), low boom (20”), fine to medium/coarse droplet size, 20 swaths, EPA-defined 

wetland, and 25-foot distance (buffer) from treated area to water. 
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Appendix E: Integrated Pest Management Program E-43 

See Section 7.2.1.2 for more details regarding the calculation of EECs for aquatic habitats for habitat 

management and cropland/facilities maintenance treatments. 

For terrestrial avian and mammalian assessments, RQ calculations would be done by Service 

personnel based upon dietary exposure, where the “short grass” food item category would represent 

the worst-case scenario. For terrestrial spray applications associated with habitat management and 

cropland/facilities maintenance treatments, exposure (EECs and RQs) would be determined using the 

Kanaga nomogram method through the USEPA’s Terrestrial Residue Exposure model (T-REX) 

version 1.2.3. T-REX input variables would include the following: max application rate (acid basis 

[see above]) and pesticide half-life (days) in soil to estimate the initial, maximum pesticide residue 

concentration on general food items for terrestrial vertebrate species in short (<20 cm tall) grass. 

For granular pesticide formulations and pesticide-treated seed with a unique route of exposure for 

terrestrial avian and mammalian wildlife, see Section 7.2.1.1.2 for the procedure that would be used 

to calculate RQs. 

All calculated RQs in both tables would be compared with Levels of Concern (LOCs) established by 

USEPA (see Table 2 in Section 7.2). If a calculated RQ exceeds an established LOC value (in 

brackets inside the table), then there would be a potential for an acute or chronic effect (unacceptable 

risk) to federally listed (T&E) species and nonlisted species. See Section 7.2 for detailed 

descriptions of acute and chronic RQ calculations and comparison to LOCs to assess risk. 

Threshold for approving PUPs: 

If RQs≤LOCs, then a PUP would be approved without additional BMPs. 

If RQs>LOCs, then a PUP would only be approved with additional BMPs specifically to minimize 

exposure (ecological risk) to bird, mammal, and/or fish species. One or more BMPs such as the 

following would be included in the Specific Best Management Practices (BMPs) section to reduce 

potential risk to nonlisted or listed species: 

 Lower application rate and/or fewer number of applications so RQs≤LOCs 

 For aquatic assessments (fish) associated with cropland/facilities maintenance, increase the 

buffer distance beyond 25’ so RQs≤LOCs. 

Justification for Use: Service personnel would describe the reason for using the pesticide based 

control of specific pests or groups of pests. In most cases, the pesticide label will provide the 

appropriate information regarding control of pests to describe in the section. 

Specific Best Management Practices (BMPs): Service personnel would record specific BMPs 

necessary to minimize or eliminate potential effects to nontarget species and/or degradation of 

environmental quality from drift, surface runoff, or leaching. These BMPs would be based upon 

scientific information documented in previous data fields of a Chemical Profile. Where necessary 

and feasible, these specific practices would be included in PUPs as a basis for approval. 

If there are no specific BMPs that are appropriate, then Service personnel would describe why the 

potential effects to Refuge resources and/or degradation of environmental quality is outweighed by 

the overall resource benefit(s) from the proposed pesticide use in the BMP section of the PUP. See 

Section 4.0 of this document for a complete list of BMPs associated with mixing and applying 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

E-44 Appendix E: Integrated Pest Management Program 

pesticides appropriate for all PUPs with ground-based treatments that would be additive to any 

necessary, chemical-specific BMPs. 

References: Service personnel would record scientific resources used to provide data/information 

for a chemical profile. Use the number sequence to uniquely reference data in a chemical profile. 

The following on-line data resources are readily available for toxicological endpoint and 

environmental fate data for pesticides: 

1. California Product/Label Database. Department of Pesticide Regulation, California 

Environmental Protection Agency. (http://www.cdpr.ca.gov/docs/label/labelque.htm#regprods) 

2. ECOTOX database. Office of Pesticide Programs, USEPA , Washington, DC. 

(http://cfpub.epa.gov/ecotox/) 

3. Extension Toxicology Network (EXTOXNET) Pesticide Information Profiles. Cooperative effort 

of University of California-Davis, Oregon State University, Michigan State University, Cornell 

University and University of Idaho through Oregon State University, Corvallis, Oregon. 

(http://extoxnet.orst.edu/pips/ghindex.html) 

4. FAO specifications and evaluations for plant protection products. Pesticide Management Unit, 

Plant Protection Services, Food and Agriculture Organization, United Nations. 

(http://www.fao.org/WAICENT/FAOINFO/AGRICULT/AGP/AGPP/Pesticid/) 

5. Human health and ecological risk assessments. Pesticide Management and Coordination, Forest 

Health Protection, US Department of Agriculture, US Forest Service. 

(http://www.fs.fed.us/foresthealth/pesticide/risk.htm) 

6. Pesticide Chemical Fact Sheets. Clemson University Pesticide Information Center. 

(http://entweb.clemson.edu/pesticid/Document/Labels/factshee.htm) 

7. Pesticide Fact Sheets. Published by Information Ventures, Inc. for BLM , Dept. of Interior; 

Bonneville Power Administration, U.S. Dept. of Energy; and Forest Service, US Department of 

Agriculture. (http://infoventures.com/e-hlth/pesticide/pest-fac.html) 

8. Pesticide Fact Sheets. National Pesticide Information Center. (http://npic.orst.edu/npicfact.htm) 

9. Pesticide Fate Database. US Environmental Protection Agency, Washington, DC. 

(http://cfpub.epa.gov/pfate/home.cfm). 

 

10. Pesticide product labels and material safety data sheets. Crop Data Management Systems, Inc. 

(CDMS) (http://www.cdms.net/pfa/LUpdateMsg.asp) or multiple websites maintained by 

agrichemical companies. 

11. Registered Pesticide Products (Oregon database). Oregon Department of Agriculture. 

(http://www.oda.state.or.us/dbs/pest_products/search.lasso) 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix E: Integrated Pest Management Program E-45 

12. Regulatory notes. Pest Management Regulatory Agency, Health Canada, Ontario, Canada. 

(http://www.hc-sc.gc.ca/pmra-arla/) 

13. Reptile and Amphibian Toxicology Literature. Canadian Wildlife Service, Environment Canada, 

Ontario, Canada. (http://www.cws-scf.ec.gc.ca/nwrc-cnrf/ratl/index_e.cfm) 

14. Specific Chemical Fact Sheet – New Active Ingredients, Biopesticide Fact Sheet and Registration 

Fact Sheet. U.S Environmental Protection Agency, Washington, DC. 

(http://www.epa.gov/pestidides/factsheets/chemical_fs.htm) 

15. Weed Control Methods Handbook: Tools and Techniques for Use in Natural Areas. The Invasive 

Species Initiative. The Nature Conservancy. (http://tnsweeds.ucdavis.edu/handbook.html) 

16. Wildlife Contaminants Online. US Geological Survey, Department of Interior, Washington, D.C. 

(http://www.pwrc.usgs.gov/contaminants-online/) 

17. One-liner database. 2000. USEPA , Office of Pesticide Programs, Washington, D.C. 

Chemical Profile 

Date: 

Trade Name(s): Common Chemical 

Name(s): 

Pesticide Type: EPA Registration 

Number: 

Pesticide Class: CAS Number: 

Other Ingredients: 

Toxicological Endpoints

Mammalian LD50: 

Mammalian LC50: 

Mammalian Reproduction: 

Avian LD50: 

Avian LC50: 

Avian Reproduction: 

Fish LC50: 

Fish ELS/Life Cycle: 

Other: 

Ecological Incident Reports 

 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

E-46 Appendix E: Integrated Pest Management Program 

Environmental Fate 

Water solubility (Sw): 

Soil Mobility (Koc): 

Soil Persistence (t1⁄2): 

Soil Dissipation (DT50): 

Aquatic Persistence (t1⁄2): 

Aquatic Dissipation (DT50): 

Potential to Move to Groundwater 

(GUS score): 

Volatilization (mm Hg): 

Octanol-Water Partition Coefficient 

(Kow): 

Bioaccumulation/Biocentration: BAF:` 

BCF: 

Worst Case Ecological Risk Assessment

Max Application 

Rate 

(ai lbs/acre – ae 

basis) 

Habitat Management: 

Croplands/Facilities Maintenance: 

EECs Terrestrial (Habitat Management): 

Terrestrial (Croplands/Facilities Maintenance): 

Aquatic (Habitat Management): 

Aquatic (Croplands/Facilities Maintenance): 

Habitat Management Treatments 

Presumption of Unacceptable Risk Risk Quotient (RQ) 

Listed (T&E) 

Species 

Nonlisted Species 

Acute Birds [0.1] [0.5] 

Mammals [0.1] [0.5] 

Fish [0.05] [0.5] 

Chronic Birds [1] [1] 

Mammals [1] [1] 

Fish [1] [1] 

Cropland/Facilities Maintenance Treatments 

Presumption of Unacceptable Risk Risk Quotient (RQ) 

Listed (T&E) 

Species Nonlisted Species 

Acute Birds [0.1] [0.5] 

Mammals [0.1] [0.5] 

Fish [0.05] [0.5] 

Chronic Birds [1] [1] 

Mammals [1] [1] 

Fish [1] [1] 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix E: Integrated Pest Management Program E-47 

Justification for Use: 

Specific Best 

Management Practices 

(BMPs): 

References: 

Table CP.1 Pesticide Name 

Trade 

Namea

Treatment 

Typeb 

Max Product 

Rate – Single 

Application 

(lbs/acre or 

gal/acre) 

Max Product 

Rate -Single 

Application 

(lbs/acre - AI 

on acid equiv 

basis) 

Max Number 

of 

Applications 

Per Season 

Max Product 

Rate Per Season 

(lbs/acre/season 

or 

gal/acre/season) 

Minimum 

Time 

Between 

Applications 

(Days) 

 

a

From each label for a pesticide identified in pesticide use proposals (PUPs), Service personnel 

would record application information associated with possible/known uses on Service lands.

b

Treatment type: H – habitat management or CF – cropland/facilities maintenance. If a pesticide is 

labeled for both types of treatments (uses), then record separate data for H and CF applications. 

 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

E-48 Appendix E: Integrated Pest Management Program 

7.7 References 

AgDrift 2001. A user’s guide for AgDrift 2.04: a tiered approach for the assessment of spray drift of 

pesticides. Spray Drift Task Force, PO Box 509, Macon, Missouri. 

ATSDR (Agency for Toxic Substances and Disease Registry) US Department of Health and Human 

Services. 2004. Guidance Manual for the Assessment of Joint Toxic Action of Chemical 

Mixtures. US Department of Health and Human Services, Public Health Service, ATSDR, 

Division of Toxicology. 62 pages plus Appendices. 

Baehr, C.H., and C. Habig. 2000. Statistical evaluation of the UTAB database for use in terrestrial 

nontarget organism risk assessment. 10th Symposium on Environmental Toxicology and Risk 

Assessment, American Society of Testing and Materials. 

Baker, J. and G. Miller. 1999. Understanding and reducing pesticide losses. Extension Publication 

PM 1495, Iowa State University Extension, Ames, Iowa. 6 pages. 

Barry, T. 2004. Characterization of propanil prune foliage residues as related to propanil use patterns 

in the Sacramento Valley, CA. Proceedings of the International Conference on Pesticide 

Application for Drift Management. Waikoloa, Hawaii. 15 pages. 

Battaglin, W.A., E.M. Thurman, S.J. Kalkhoff, and S.D. Porter. 2003. Herbicides and 

Transformation Products in Surface Waters of the Midwestern United States. Journal of the 

American Water Resources Association (JAWRA) 39(4):743-756. 

Beyer, W.N., E.E. Connor, S. Gerould. 1994. Estimates of soil ingestion by wildlife. Journal of 

Wildlife Management 58:375-382. 

Brooks, M.L., D'Antonio, C.M., Richardson, D.M., Grace, J.B., Keeley, J.E. and others. 2004. 

Effects of invasive alien plants on fire regimes. BioScience 54:77-88. 

BLM . 2007. Vegetation treatments using herbicides on BLM Lands in 17 western states 

Programmatic EIS (PEIS). Washington Office, BLM . 

Butler, T., W. Martinkovic, and O.N. Nesheim. 1998. Factors influencing pesticide movement to 

ground water. Extension Publication PI-2, University of Florida, Cooperative Extension 

Service, Gainesville, FL. 4 pages. 

Calabrese, E.J. and L.A. Baldwin. 1993. Performing Ecological Risk Assessments. Lewis 

Publishers, Chelsea, MI. 

Center, T.D., Frank, J.H., and Dray Jr., F.A. 1997. Biological Control. Strangers in Paradise: Impact 

and Management of Nonindigenous Species in Florida. P.245-263. 

Cox, R.D., and V.J. Anderson. 2004. Increasing native diversity of cheatgrass-dominated rangeland 

through assisted succession. Journal of Range Management 57:203-210. 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix E: Integrated Pest Management Program E-49 

Coombs, E.M., J.K Clark, G.L. Piper, and A.F. Cofrancesco Jr. 2004. Biological control of invasive 

plants in the United States. Oregon State University Press, Corvallis, 467 pages. 

Driver, C.J., M.W. Ligotke, P. Van Voris, B.D. McVeety, B.J. Greenspan, and D.B. Brown. 1991. 

Routes of uptake and their relative contribution to the toxicologic response of northern 

bobwhite (Colinus virginianus) to an organophosphate pesticide. Environmental Toxicology 

and Chemistry 10:21-33. 

Dunning, J.B. 1984. Body weights of 686 species of North American birds. Western Bird Banding 

Association. Monograph No. 1. 

EXTOXNET. 1993a. Movement of pesticides in the environment. Pesticide Information Project of 

Cooperative Extension Offices of Cornell University, Oregon State University, University of 

Idaho, University of California – Davis, and the Institute for Environmental Toxicology, 

Michigan State University. 4 pages. 

Fletcher, J.S., J.E. Nellessen, and T.G. Pfleeger. 1994. Literature review and evaluation of the EPA 

food-chain (Kenaga) nomogram, and instrument for estimating pesticide residue on plants. 

Environmental Toxicology and Chemistry 13:1381-1391. 

Hasan, S. and P.G. Ayres. 1990. The control of weeds through fungi: principles and 

prospects. Tansley Review 23:201-222. 

Huddleston, J.H. 1996. How soil properties affect groundwater vulnerability to pesticide 

contamination. EM 8559. Oregon State University Extension Service. 4 pages. 

Kerle, E.A., J.J. Jenkins, P.A. Vogue. 1996. Understanding pesticide persistence and mobility for 

groundwater and surface water protection. EM 8561. Oregon State University Extension 

Service. 8 pages. 

Masters, R.A, and R.L. Sheley. 2001. Invited synthesis paper: principles and practices for managing 

rangeland invasive plants. Journal of Range Manage 54:502-517. 

Masters, R.A., S.J. Nissen, R.E. Gaussoin, D.D. Beran, and R.N. Stougaard. 1996. Imidazolinone 

herbicides improve restoration of Great Plains grasslands. Weed Technology 10:392-403. 

Maxwell, B.D., E. Lehnhoff, L.J. Rew. 2009. The rationale for monitoring invasive plant 

populations as a crucial step for management. Invasive Plant Science and 

Management 2:1-9. 

Mineau, P., B.T. Collins, and A. Baril. 1996. On the use of scaling factors to improve interspecies 

extrapolation to acute toxicity in birds. Regulatory Toxicology and Pharmacology 24:24-29. 

Moody, M.E., and R.N. Mack. 1988. Controlling the spread of plant invasions: the importance of 

nascent foci. Journal of Applied Ecology 25:1009-1021. 

Morse, L.E., J.M. Randall, N. Benton, R. Hiebert, and S. Lu. 2004. An Invasive Species Assessment 

Protocol: NatureServe. 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

E-50 Appendix E: Integrated Pest Management Program 

Mullin, B.H., L.W. Anderson, J.M. DiTomaso, R.E. Eplee, and K.D. Getsinger. 2000. 

Invasive Plant Species. Issue Paper (13):1-18. 

Oregon State University. 1996. EXTOXNET-Extension Toxicology Network, Pesticide Information 

Profiles. Oregon State University, Corvallis, Oregon. 

Pfleeger, T.G., A. Fong, R. Hayes, H. Ratsch, C. Wickliff. 1996. Field evaluation of the EPA 

(Kanaga) nomogram, a method for estimating wildlife exposure to pesticide residues on 

plants. Environmental Toxicology and Chemistry 15:535-543. 

Pope, R., J. DeWitt, and J. Ellerhoff. 1999. Pesticide movement: what farmers need to know. 

Extension Publication PAT 36, Iowa State University Extension, Ames, Iowa and Iowa 

Department of Agriculture and Land Stewardship, Des Moines, Iowa. 6 pages. 

Ramsay, C.A., G.C. Craig, and C.B. McConnell. 1995. Clean water for Washington – protecting 

groundwater from pesticide contamination. Extension Publication EB1644, Washington State 

University Extension, Pullman, Washington. 12 pages. 

SDTF 2003 Spray Drift Task Force. 2003. A summary of chemigation application studies. Spray 

Drift Task Force, Macon, Missouri. 

Teske, M.E., S.L. Bird, D.M. Esterly, S.L. Ray, S.G. and Perry. 1997. A User's Guide for 

AgDRIFTTM 1.0: A Tiered Approach for the Assessment of Spray Drift of Pesticides, 

Technical Note No. 95-10, CDI, Princeton, New Jersey. 

Teske, M.E., S.L. Bird, D.M. Esterly, T.B. Curbishley, S.L. Ray, and S.G. Perry. 2002. 

AgDRIFT®: a model for estimating near-field spray drift from aerial applications. 

Environmental Toxicology and Chemistry 21: 659-671. 

Urban, D.J and N.J. Cook. 1986. Ecological risk assessment. EPA 540/9-85-001. USEPA , Office 

of Pesticide Programs, Washington D.C. 94 pages. 

USEPA . 1990. Laboratory Test Methods of Exposure to Microbial Pest Control Agents by the 

Respiratory Route to Nontarget Avian Species. Environmental Research Laboratory, 

Corvallis, OR. EPA/600/3-90/070. 

USEPA . 1998. A Comparative Analysis of Ecological Risks from Pesticides and Their Uses: 

Background, Methodology & Case Study. Environmental Fate & Effects Division, Office of 

Pesticide Programs, U.S. Environmental Protection Agency, Washington, D.C. 105 pages. 

USEPA . 2004. Overview of the ecological risk assessment process in the Office of Pesticide 

Programs, USEPA : endangered and threatened species effects determinations, Office of 

Pesticide Programs, Washington, DC. 101 pages. 

USEPA . 2005a. Technical overview of ecological risk assessment risk characterization; 

Approaches for evaluating exposure; Granular, bait, and treated seed applications. USEPA , 

Office of Pesticide Programs, Washington, DC. 

http://www.epa.gov/oppefed1/ecorisk_ders/toera_analysis_exp.htm. 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix E: Integrated Pest Management Program E-51 

USEPA . 2005b. User’s Guide TREX v1.2.3. USEPA , Office of Pesticide Programs, Washington, 

DC. 22 pages. http://www.epa.gov/oppefed1/models/terrestrial/trex_usersguide.htm. 

U.S. Geological Survey. 2000. Pesticides in stream sediment and aquatic biota – current 

understanding of distribution and major influences. USGS Fact Sheet 092-00, US Geological 

Survey, Sacramento, California. 4 pages. 

U.S. Forest Service. 2005. Pacific Northwest Region Invasive Plant Program 

Preventing and Managing Invasive Plants Final Environmental Impact Statement. 359 pages. 

Wauchope, R.D., T.M. Buttler, A.G. Hornsby, P.M. Augustijn-Beckers, and J.P. Burt. 1992. The 

SCS/ARS/CES pesticide properties database for environmental decision making. Reviews of 

Environmental Contamination and Toxicology 123:1-155. 

Woods, N. 2004. Australian developments in spray drift management. Proceedings of the 

International Conference on Pesticide Application for Drift Management, Waikoloa, Hawaii. 

8 pages. 

 
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E-52 Appendix E: Integrated Pest Management Program 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix F: ESA Section 7 Consultations F-1 

Appendix F: ESA Section 7 Consultation 











Appendix G: WILDLAND FIRE MANAGEMENT PLAN 

KEĀLIA POND NATIONAL WILDLIFE REFUGE 

Kīhei, Maui, Hawaii 

2004
2004 WILDLAND FIRE MANAGEMENT PLAN 

KEĀLIA POND NATIONAL WILDLIFE REFUGE 

Prepared: 

Glynnis L. Nakai, Refuge Manager Date 

Maui National Wildlife Refuge Complex 

Concurred: 

Jerry Leinecke, Project Leader Date 

Hawaiian and Pacific Islands National Wildlife Refuge Complex 

Concurred: 

Pamela Ensley, Regional Fire Management Coordinator Date 

Pacific Region, U.S. Fish and Wildlife Service 

Approved: 

David B. Allen, Regional Director Date 

Pacific Region, U.S. Fish and Wildlife Service 
iii

TABLE OF CONTENTS 

LIST OF FIGURES ....................................................................................................................................v

LIST OF TABLES ......................................................................................................................................v

INTRODUCTION .......................................................................................................................................1

COMPLIANCE WITH USFWS POLICY................................................................................................ 2

Refuge Purpose ................................................................................................................................ 2

Refuge Goals ....................................................................................................................................2

FIRE MANAGEMENT OBJECTIVES ....................................................................................................4

DESCRIPTION OF REFUGE ...................................................................................................................5

General Description.......................................................................................................................... 5

Climate .............................................................................................................................................5

Vegetation ........................................................................................................................................5

Fish and Wildlife .............................................................................................................................. 5

Threatened and Endangered Species ................................................................................................ 6

Cultural Resources ........................................................................................................................... 6

Physical Resources ........................................................................................................................... 7

Structures and Facilities ...................................................................................................................7

Public Use and Access .....................................................................................................................7

WILDLAND FIRE MANAGEMENT SITUATION ...............................................................................9

Historic Role of Fire ......................................................................................................................... 9

Pre-settlement Fires .............................................................................................................9

Post-settlement Fire History ................................................................................................ 9

Prescribed Fire History ........................................................................................................9

Responsibilities ................................................................................................................................ 9

Refuge Manager ..................................................................................................................9

Biologist ............................................................................................................................ 10

Zone Fire Management Officer ......................................................................................... 10

Incident Commander .........................................................................................................10

Interagency Operations ...................................................................................................................11

Protection of Sensitive Resources ..................................................................................................12

WILDLAND FIRE SUPPRESSION ACTIVITIES ...............................................................................14

Fire Management Strategies ...........................................................................................................14

Preparedness ...................................................................................................................................14

Historical Weather Analysis .............................................................................................. 14

Fire Prevention ..................................................................................................................15

Hazard Reduction for Structure Protection .......................................................................15

Staffing Priority Levels .....................................................................................................15

Training ............................................................................................................................. 15

Supplies and Equipment ....................................................................................................16

Detection ........................................................................................................................................16
iv

Communications ............................................................................................................................ 16

Pre-Attack Plan .............................................................................................................................. 16

Fire Management Units ..................................................................................................................16

Fuels and Fire Behavior .................................................................................................................17

Fuel Types and Fire Behavior ........................................................................................... 17

Fire Effects ........................................................................................................................ 18

Suppression Tactics ........................................................................................................................ 18

Suppression Conditions .....................................................................................................19

Wildland Fire Situation Analysis ......................................................................................19

Aircraft Operations ............................................................................................................20

Burned Area Emergency Stabilization and Rehabilitation ............................................................. 20

Policy and Implementation Guidance ................................................................................20

Compliance ....................................................................................................................... 20

Required Reporting ........................................................................................................................ 21

Fire Investigation ............................................................................................................................ 21

HAZARD FUEL REDUCTION ..............................................................................................................22

Hazard Fuel Reduction Strategies ..................................................................................................22

Pile Burning Guidelines .................................................................................................................22

Pile Burn Plan ...................................................................................................................23

Pile Burning Strategies and Personnel ..............................................................................23

Monitoring and Evaluation ................................................................................................ 24

Required Reports ...............................................................................................................24

AIR QUALITY / SMOKE MANAGEMENT GUIDELINES ............................................................... 25

FIRE RESEARCH ....................................................................................................................................25

PUBLIC SAFETY .....................................................................................................................................26

PUBLIC INFORMATION AND EDUCATION ....................................................................................26

FIRE CRITIQUES AND ANNUAL PLAN REVIEW ...........................................................................27

Fire Critiques ..................................................................................................................................27

Annual Fire Summary Report ........................................................................................................27

Annual Fire Management Plan Review .......................................................................................... 27

CONSULTATION AND COORDINATION ......................................................................................... 27

APPENDICES ...........................................................................................................................................28

Appendix A: References Cited ..................................................................................................28

Appendix B: Definitions ............................................................................................................29

Appendix C: Fire Dispatch Plan ................................................................................................ 32

Appendix D: NEPA Compliance ............................................................................................... 36

Appendix E: ESA Section 7 Compliance ..................................................................................38

Appendix F: Request for Cultural Resource Compliance ......................................................... 41

Appendix G: Interagency Agreements ....................................................................................... 43

Appendix H: Pile Burn Plan Template ......................................................................................44

Appendix I: Delegation of Authority........................................................................................ 53

Appendix J: Wildland Fire Situation Analysis .........................................................................54
v 

LIST OF FIGURES 

Figure 1. Keālia Pond National Wildlife Refuge .......................................................................................... 8

Figure 2. Fire Response Zones for the Island of Maui ...............................................................................12

LIST OF TABLES 

Table 1. Threatened and Endangered Species Found at Keālia Pond NWR ................................................6

Table 2. Habitat types and fuel models on Keālia Pond NWR ...................................................................17

Table 3. Backing fire behavior predictions for Keālia Pond NWR in Fuel Models 1 and 3 ....................... 18

Table 4. Keālia Pond NWR Wildland Fire Suppression Guidelines .......................................................... 19

Table 5. Maui National Wildlife Refuge Complex Staff. ...........................................................................35

Table 6. Landowners adjacent to Keālia Pond NWR .................................................................................35
1 

INTRODUCTION 

This document will establish a Fire Management Plan for Keālia Pond National Wildlife Refuge (NWR), 

of the Maui NWR Complex. This plan will meet the requirements of the National Environmental Policy 

Act (NEPA), the Endangered Species Act (ESA) and the National Historic Preservation Act (NHPA). 

Compliance with NEPA was met through a Categorical Exclusion and associated Environmental Action 

Statement (Appendix D). For ESA Section 7 compliance, informal consultation with Ecological Services 

led to May Affect, Not Likely to Adversely Affect determination (Appendix E). Compliance with the 

NHPA will be accomplished at the project level through submission of a Request for Cultural Resources 

Compliance form (Appendix F) to the Regional Archaeologist. 

This plan is written as an operational guide for managing the refuge's wildland fire and prescribed fire 

programs. It defines levels of protection needed to provide for safety, protect facilities and resources, and 

restore and perpetuate natural processes, given current understanding of the complex relationships in 

natural ecosystems. It is written to comply with a service-wide requirement that refuges with burnable 

vegetation develop a fire management plan (620 DM 1). 

This plan will outline a program of suppression of all wildland fires and pile burning (as a limited form of 

prescribed fire). These piles will be generated from habitat enhancement and maintenance activities 

covered within the refuge’s ESA documentation. 

There is no dedicated fire management staff on the refuge. Fire Management oversight is provided by the 

Regional Office located in Portland. Day-to-day fire management responsibilities are provided by the 

Refuge Manager located onsite. Suppression of wildland and structural fires on the refuge will be 

provided by Maui County Fire Department, Kahului Station, based on County of Maui emergency policy. 
2 

COMPLIANCE WITH USFWS POLICY 

Keālia Pond National Wildlife Refuge was established in 1992 to provide nesting and maintenance habitat 

for three native Hawaiian endangered waterbirds as well as migratory waterfowl and shorebirds. The 

endangered waterbirds include Hawaiian stilt (Himantopus mexicanus knudseni), Hawaiian coot (Fulica 

alai), and Hawaiian duck (Anas wyvilliana).

This plan meets NEPA / NHPA compliance and will be implemented in cooperation with the Endangered 

Species Act of 1973, as amended, and will take appropriate action to identify and protect from adverse 

effects on any rare, threatened, or endangered species. Compliance with NEPA was met through a 

Categorical Exclusion and associated Environmental Action Statement (Appendix D). For ESA Section 7 

compliance, informal consultation with Ecological Services led to a “May Affect, Not Likely to Adversely 

Affect” determination (Appendix E). Compliance with the NHPA will be accomplished at the project 

level through submission of a Request for Cultural Resources Compliance form (Appendix F) to the 

Regional Archaeologist. 

At this time, no Master Plan or Comprehensive Conservation Plan (CCP) exists for the Refuge. 

Development of a CCP for the entire complex is scheduled to begin in 2006. An interim Management 

Plan for Keālia Pond National Wildlife Refuge was developed in 2001 (U.S. Fish and Wildlife Service 

2001) that identified the goals of the Refuge, objectives supporting those goals, and strategies addressing 

each objective. The Refuge purpose and goals can be found in the Maui National Wildlife Refuge 

Complex’s Refuge Management Information System, and are as follows: 

REFUGE PURPOSE

“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). 

REFUGE GOALS

Endangered Species: Promote the conservation of endangered species, especially native 

Hawaiian coot and Hawaiian stilt through healthy functioning of this wetland floodplain. 

Habitat: Optimize water levels for maximum habitat size and value for endangered, resident, and 

migrating waterfowl and shorebirds while reducing the growth and reproduction of problematical 

exotic species. 

Visitor Use: Expand understanding and appreciation of the environment through wildlifeoriented educational opportunities. Provide opportunities for quality, wildlife-dependent 

recreation, education, and research to enhance public appreciation, understanding, and enjoyment 

of refuge wildlife and habitats. 

Habitat Restoration: Restore and maintain the diversity and abundance of native species 

naturally occurring on the Refuge. 

Authority and guidance for implementing this plan are found in: 

Protection Act of September 20, 1922 (42 Stat. 857; 16 U.S.C.594): authorizes the Secretary of the 

Interior to protect from fire, lands under the jurisdiction of the Department directly or in 

cooperation with other Federal agencies, states, or owners of timber. 

Economy Act of June 30, 1932: authorizes contracts for services with other Federal agencies. 

Reciprocal Fire Protection Act of May 27, 1955 (69 Stat. 66, 67; 42 U.S.C. 1856, 1856a and b): 

authorizes reciprocal fire protection agreements with any fire organization for mutual aid with or 
3 

without reimbursement and allows for emergency assistance in the vicinity of agency lands in 

suppressing fires when no agreement exists. 

Disaster Relief Act of May 22, 1974 (88 Stat. 143; 42 U.S.C. 5121): authorizes Federal agencies 

to assist state and local governments during emergency or major disaster by direction of the 

President. 

National Wildlife Refuge System Administrative Act of 1966 as amended by the National Wildlife 

Refuge System Improvement Act of 1997, 16 U.S.C. 668dd et seq.: defines the National Wildlife 

Refuge System as including wildlife refuges, areas for the protection and conservation of fish and 

wildlife which are threatened with extinction, wildlife ranges, game ranges, wildlife management 

areas and waterfowl production areas. It also establishes a conservation mission for the Refuge 

System, defines guiding principles and directs the Secretary of the Interior to ensure that biological 

integrity and environmental health of the system are maintained and that growth of the system 

supports the mission. 

Federal Fire Prevention and Control Act of October 29, 1974 (88 Stat. 1535; 15 U.S.C.2201): 

provides for reimbursement to state or local fire services for costs of firefighting on federal 

property. 

Wildfire Suppression Assistance Act of 1989. (Pub.L. 100-428, as amended by Pub.L 101- 11, 

April 7, 1989). 

Departmental Manual (Interior), Part 620 DM, Chapter 1, Wildland Fire Management: General 

Policy and Procedures (April 10, 1998): defines Department of Interior fire management policies. 

Service Manual, Part 621, Fire Management (February 7, 2000): defines U.S. Fish and Wildlife 

Service fire management policies. 

National Environmental Policy Act of 1969: regulations implementing the National 

Environmental Policy Act (NEPA) encourages the combination of environmental comments with 

other agency documents to reduce duplication and paperwork (40 CFR 1500.4(o) and 1506.4). 

Clean Air Act (42 United State Code (USO) 7401 et seq.): requires states to attain and maintain 

the national ambient air quality standards adopted to protect health and welfare. This encourages 

states to implement smoke management programs to mitigate the public health and welfare 

impacts of Wildland and prescribed fires managed for resource benefit. 

Endangered Species Act of 1973. 

U.S. Fish & Wildlife Service Fire Management Handbook. 

The authority for funding (normal fire year programming) and all emergency fire accounts is found in the 

following authorities: 

Section 102 of the General Provisions of the Department of Interior's annual Appropriations Bill 

provides the authority under which appropriated monies can be expended or transferred to fund 

expenditures arising from the emergency prevention and suppression of wildland fire. 

P.L. 101-121, Department of the Interior and Related Agencies Appropriation Act of 1990, 

established the funding mechanism for normal year expenditures of funds for fire management 

purposes. 

31 US Code 665(E)(1)(B) provides the authority to exceed appropriations due to wildland fire 

management activities involving the safety of human life and protection of property. 

Authorities for procurement and administrative activities necessary to support wildland fire suppression 

missions are contained in the Interagency Fire Business Management Handbook. 
4 

FIRE MANAGEMENT OBJECTIVES 

The overall objective for fire management on Keālia Pond NWR is to promote a program to provide for 

firefighter and public safety, reduce the incidence of human-caused fires, and ensure appropriate 

suppression response capability to meet expected wildland fire complexity. Wildland fire potential exists 

on the refuge due to the proximity to sugar cane operations along the north side of the refuge and beach 

sites along Ma’alaea Flats. Specific fire management objectives are: 

Promote a fire management program and control all wildland fires. 

Provide for the protection of life, property, and resources from wildland fires at costs 

commensurate with resource values at risk. 

Use appropriate suppression tactics and strategies that minimize long-term impacts of suppression 

actions. 

Use pile burning to safely and efficiently remove debris from resource management activities and 

reduce hazardous fuels. 
5 

DESCRIPTION OF REFUGE 

GENERAL DESCRIPTION

Keālia Pond National Wildlife Refuge is located adjacent to Ma’alaea Bay, along the south central coast on 

the Island of Maui, Hawai’i (Figure 1). The 700-acre refuge is a naturally formed wetland within the 

isthmus separating the West Maui Mountains and Haleakala. The property is bisected by North Kihei 

Road (Highway 31), separating the main pond from the coastal dune and mudflats habitat. The nearest 

community, Kihei, is located southeast of the refuge boundary. 

The refuge is comprised of approximately 200 acres of open water (Keālia Pond proper), 350 acres of 

mudflats and 200 acres of scrub-shrub and upland habitats bordering the wetlands. In 1970, aquaculture 

ponds (25 acres) were constructed at the north side of the main pond where the refuge office is located. 

The aquaculture operation terminated in 1995 and the ponds (Kanuimanu Ponds) are now managed for 

waterbird and visitor use. 

CLIMATE

The refuge receives five to 20 inches of rain annually. Mean monthly rainfall averages less than five 

inches. Mean maximum daily temperatures are in the high 70s and 80s (°F). The average annual 

temperature is approximately 74°F with August to October having the warmest months of the year. 

Warmest weather occurs with “Kona” weather. Seasonal and diurnal variability in cloud cover occur with 

clouds tending to be more abundant during the day. Average daily relative humidity ranges from 65% to 

90%. 

VEGETATION

The vegetative communities of the refuge vary from wetland to upland habitats. Vegetation is primarily 

non-native, invasive plants which have formed large, monotypic stands. Mudflats are predominantly 

pickleweed (Batis maritima), which forms dense, tall mats of old growth. Moist soil areas along the dikes 

have dense coverage of Indian marsh fleabane (Pluchea indica), and upland areas along the north 

boundary consist of kiawe or mesquite (Prosopis pallida), common ironwood (Casuarina equisetifolia), 

Australian saltbush (Atriplex semibaccata), castor bean (Ricinus communis), koa haole (Leucaena 

leucocephala), and various grasses (Brachiaria mutica, Cenchrus ciliaris, Cynodon dactylon, and 

Leptochloa uninervia). Large stands of American mangrove (Rhizophora mangle) and California bulrush 

(Schoenoplectus californicus) occur along the eastern edge of the wetland. The weather conditions on 

Maui promotes year-round growing season resulting in dense understory in most areas. 

FISH AND WILDLIFE

Keālia Pond NWR was established to protect and manage endangered waterbird populations (Hawaiian 

stilt and Hawaiian coot) and their habitats. The pond is one of the last natural wetlands remaining within 

the Hawaiian islands and is also host to more than 20 species of migratory waterfowl, including Northern 

shoveler (Anas clypeata), Northern pintail (Anas acuta), scaup (Aythya spp.), and American wigeon (Anas 

americana), and shorebirds including wandering tattler (Heteroscelus incanus), sanderling (Calidris alba), 

and ruddy turnstone (Arenaria interpres). The Refuge also contains populations of other native species 

including black-crowned night heron (Nycticorax nycticorax) and short-eared owl or pueo (Asio flammeus 

sandwichensis), and non-native cattle egrets (Bubulcus ibis). Numerous non-native passerines are present 

within the upland habitat, including spotted doves (Streptopelia chinensis), zebra doves (Geopelia striata), 

common myna (Acridotheres tristis), Northern cardinal (Cardinalis cardinalis), house finch (Carpodacus

mexicanus), orange-cheeked waxbill (Estrilda melpoda), and gray francolin (Francolinus pondicerianus). 
6 

Fish population consists of predominantly introduced tilapia (Tilapia spp.), and mosquito fish (Gambusia

sp.). Mammals found on the refuge are all non-native and include black rat (Rattus rattus), Norwegian rat, 

feral cats, and mongoose, all of which are controlled to protect endangered waterbirds. 

THREATENED AND ENDANGERED SPECIES

Endangered waterbirds at Keālia Pond NWR include the Hawaiian stilt, Hawaiian coot, and historically, 

the Hawaiian duck. The latter species has hybridized with local mallards (non-migratory) resulting in 

physical characteristics that are difficult to distinguish; therefore, it is possible the pure species is present 

but not nesting on the refuge. Depending upon water levels Hawaiian stilts and coots use a majority of the 

main pond and mudflats. Hawaiian stilts are limited to shallow water (approximately seven inches or less) 

and nest (April through August) on the ground adjacent to water and vegetation. Hawaiian coots prefer 

deeper water (18 inches or less) for nesting (December through March/April) but are also present in 

shallow water along the water’s edge. The critical period for both waterbirds is from December through 

August during their breeding season. 

The endangered hawksbill sea turtle (Eretmochelys imbricata) is known to nest on the adjacent Keālia 

Beach, but is not found on the refuge. Nesting season occurs from May through September/October. 

A majority of the vegetation present on the refuge is non-native, invasive species; there is no threatened or 

endangered plant species recorded. The refuge does not contain designated Critical Habitat or portions 

thereof, does not possess any areas designated as Critical Habitat 

Table 1. Threatened and Endangered Species Found at Keālia Pond NWR.

Common Name Scientific Name Federal Status

Hawaiian Duck Anas wyvilliana Endangered

Hawaiian Coot Fulica alai Endangered

Hawaiian Stilt Himantopus mexicanus knudseni Endangered

Hawksbill Sea Turtle* Eretmochelys imbricata* Endangered

* Nests on adjacent Keālia Beach, but not found on the refuge. 

CULTURAL RESOURCES

The Service has not conducted a comprehensive archaeological survey on the refuge; however, small sites 

have been surveyed and evaluated by the State Historic Preservation Office prior to construction of visitor 

service facilities (Keālia Coastal Boardwalk) and an area adjacent to the entrance road off Mokulele 

Highway. Other site-specific surveys will be conducted prior to any land-altering activities on the refuge. 

As well as being an important source of salt, Keālia Pond was once used as a fish pond. About 400 years 

ago, the people living around the bay built ditches and sluice gates through the coastal dune, allowing 

nearshore fish into the pond. A rock platform near the refuge may once have been a heiau or fishing 

shrine. 

During World War II, 5000 soldiers of the 2nd and 4th Marine Divisions used the area as a training site. 

Remnants of a firing range and airstrip lie just outside the refuge boundary. In 1943 and 1944, in 
7 

preparation for the Marianas campaign, amphibious landings using LSTs were practiced on the refuge 

beachfront and mudflats. 

PHYSICAL RESOURCES

Elevation of Keālia Pond National Wildlife Refuge ranges from sea level to 10 feet. The soils are poorlydrained and have a high salt content. A majority of the soil has been characterized as a Keālia silt loam 

and contains relatively high salt content. During periods of heavy rain and surface runoff, ponding occurs 

in many areas. When dry, salt crystals accumulate on the surface. Soil profiles indicate a dark reddishbrown silt loam in the top three inches and stratified layers of silt loam, loam, and fine sandy loam below. 

Mean annual soil temperature is approximately 75°F. 

Wind conditions on the refuge are relatively constant. Due to the refuge’s location between the mountains, 

a vortex and funneling occurs with trade winds typically blowing from the northeast side of the island. 

South winds (“Kona”) occur periodically throughout the year. Wind speed ranges from eight to 12 knots 

(9-14 miles per hour), typically less in the early morning hours. 

The topography of the entire refuge ranges from sea level to no more than ten feet elevation that acts as a 

settling basin for approximately 56-square miles of the West Maui Mountains. Water from this watershed 

sheetflows into the refuge from three streams: Pohakea, Paleaahu, and Waikapu. Two streams, Pulehu and 

Kolalau, enter the refuge from Haleakala; however, streamflow is infrequent (one to two times per year). 

All these streams are diverted into reservoirs or ditches for agricultural purposes (primarily sugar cane 

which is adjacent to the refuge’s northern boundary). The typical hydrology of the refuge is characterized 

by high water conditions (maximum 4.8 feet above sea level) during winter months (November-March) 

and shallow water during summer, with lowest water levels in September-October. In most years, 

supplemental pumping of water is performed beginning in August to provide shallow water feeding 

conditions for waterbirds and minimize wind blown sediment to the adjacent community. 

STRUCTURES AND FACILITIES

The Refuge Headquarters is situated on the north side of the Kanuimanu ponds and consists of an elevated, 

double-wide (56 ft x 38 ft) trailer building. Above-ground holding tanks are located under the building. 

The maintenance area is located off Mokulele Highway (Highway 311) approximately 0.2 mile along the 

entrance road. This area contains metal storage containers (2 at 30 ft x 12 ft and one at 50 ft x 12 ft) and 

parking area for Refuge vehicles (5) and equipment (bobcat, tractor, portable pump, 14-ft boat and trailer). 

A greenhouse is located across the maintenance area. 

Structures are also located at the old baitfish ponds on the northeast side of the refuge and include one 

metal container for storage, one wooden building for environmental education, and one aluminum storage 

shed. Other facilities on the Refuge include three pumps with miscellaneous valves on groundwater wells, 

two of which have wooden roofs, various water distribution pipes (PVC and transite), and recycled 

materials for fencing (installed at Ma’alaea Flats and stored at Baitfish pond site). The public use areas 

include the refuge office and a 2,200 feet elevated boardwalk. The latter facility is located at Ma’alaea 

Flats on the south side of North Kihei Road (Highway 31). 

PUBLIC USE AND ACCESS

A majority of the Refuge is inaccessible for vehicles due to the flooded and/or moist soil conditions. 

Vehicle use and the general public are limited to levees of the Kanuimanu Ponds. Hiking is allowed on 

designated trails. Hunting, fishing, camping, and off-road vehicles are prohibited at all times. 
8 

Figure 1. Keālia Pond National Wildlife Refuge. 
9 

WILDLAND FIRE MANAGEMENT SITUATION 

HISTORIC ROLE OF FIRE

Historic natural fires on Maui have been limited to volcanic eruptions and lightning and are very 

infrequent. In general the native vegetation is not well adapted to fire disturbances. Non-native (invasive) 

species typically colonize burned areas to the exclusion of native species. 

Pre-settlement Fires 

There is no clear indication that fire was an integral part of the native ecosystem. There are no records 

indicating fire frequency prior to settlement, although rare fire events likely occurred as a result of volcanic 

activity and lightning. 

Post-settlement Fire History 

In the 10 year history of the refuge there have been four known wildland fires. Three of these fires were 

due to sugar cane operations adjacent to the refuge and one was the result of beach activity. The largest of 

the four known fires was 47 acres in September of 2001; the fire was caused by an escaped cane burn. All 

fires required assistance from Maui County. Throughout the state, fire season is considered by the Hawaii 

Department of Forestry and Wildlife (DOFAW) to occur during a three-month period in late summer. 

However, given the extreme variability of weather in Hawaii, fires may occur at any time during the year. 

There is no clearly-defined fire season for the refuge. 

Prescribed Fire History 

There is no history of prescribed fire use on the refuge. Prescribed burns (piles) will only be performed in 

September when endangered waterbirds are not breeding and before the influx of migratory shorebirds and 

waterfowl. 

RESPONSIBILITIES

Keālia Pond NWR does not have a dedicated fire management organization. The Project Leader and 

Refuge Manager are responsible for planning and implementing the fire management program on the 

Refuge. Staff from the Regional Office in Portland will act as the Zone Fire Management Officer (FMO), 

and are responsible for fire management program oversight. The Project Leader will assign fire 

management responsibilities as collateral duties to staff who possess appropriate training, experience, and 

incident qualifications. Preparedness planning and work is accomplished by Refuge staff in accordance 

with national and regional fire management direction under guidance from the Regional Office. 

Emergency fire management actions will be handled by Refuge staff according to training and incident 

qualifications. The Regional Office will be immediately notified of all emergency actions. Additional 

information and direction is included in the Fire Dispatch Plan (Appendix C). 

Refuge Manager 

Is responsible for implementation of all fire management activities within the Refuge and will 

ensure compliance with Department and Service policies. 

Selects the appropriate management responses to wildland fires. 

Approves any Pile Burn Plan. 

Coordinates Complex programs to ensure personnel and equipment are made available and utilized 

for fire management activities. 

Ensures that the fire management program is considered during refuge-related planning and 

project implementation. 

Acts as the primary Resource Advisor during fire management planning and operations. 

Coordinates with cooperators to ensure adequate resources are available for fire operational needs. 
10

Biologist 

Coordinates through Project Leader to provide biological input for the fire program. 

Participates, as requested in fire suppression and rehabilitation projects according to level of 

training and qualifications. 

May act as primary Refuge Resource Advisor for the Project Leader. 

Zone Fire Management Officer 

Responsible for all fire-related planning for the Refuge. 

Solicits program input from the Project Leader and Biologist. 

Coordinates fire related training. 

Coordinates with cooperators to ensure adequate resources are available for fire operational needs. 

Is responsible for preparation of fire reports following the suppression of wildland fires. 

Prepares an annual report detailing fire activities undertaken in each calendar year. This report 

will serve as a post-year’s fire management activities review, as well as provide documentation for 

development of a comprehensive fire history record for the Complex. 

Submits budget requests and monitors FIREBASE funds. 

Maintains records for all personnel involved in related activities, detailing each individual's 

qualifications and certifications for such activities. 

Incident Commander 

Incident Commanders (ICs) of any level use strategies and tactics as directed by the Project Leader and 

WFSA where applicable to implement selected objectives on a particular incident. A specific Limited 

Delegation of Authority (Appendix I) will be provided to each Incident Commander prior to assuming 

responsibility for an incident. Major duties of the Incident Commander are given in the National Wildfire 

Coordinating Group (NWCG) Fireline Handbook, including: 

Brief subordinates, direct their actions, and provide work tools. 

Ensure that safety standards identified in the Fire Orders, the Watch Out Situations, and agency 

policies are followed at all times. 

Personally scout and communicate with others to be knowledgeable of fire conditions, fire 

weather, tactical progress, safety concerns and hazards, condition of personnel, and needs for 

additional resources. 

Order resources to implement the management objectives for the fire. 

Inform appropriate dispatch of current situation and expected needs. 

Coordinate mobilization and demobilization with dispatch and the Zone FMO. 

Perform administrative duties, i.e., approving work hours, completing fire reports for command 

period, maintaining property accountability, providing or obtaining medical treatment, and 

evaluating performance of subordinates. 

Assure aviation safety is maintained to the highest standards. 

Resource Advisor

The Resource Advisor (RA) is a technical specialist appointed by the Agency Administrator and reports to 

the IC or designee and provides guidance for natural and cultural resource protection from suppression 

operations. The RA provides input to the IC in the development of fire suppression strategies and tactics 

to minimize or mitigate the expected impacts of fire and fire and fire suppression actions upon natural and 

cultural resources. The RA also provides input required for the development of rehabilitation plans. 

Resource Advisor responsibilities include (NWCG 1996): 

Provides analysis, information, and advice to fire managers for areas of concern, including critical 

watersheds, riparian areas, fisheries, and water sources; threatened or endangered species; 
11

prehistoric and historic archaeological sites and cultural landscapes; fuel breaks B locations and 

specifications; urban interface impact B structures and improvements; and hazardous materials 

Assists the planning function in developing fire maps and identifying areas of concern 

Determines environmental restrictions commensurate with FMP resource protection in the fire area 

Provides recommendations to fire management personnel and agency administrators for fire 

suppression rehabilitation needs 

Documents potential and actual suppression/fire-related resource impacts and the rationale for 

protection of priority areas 

Provides resource information to local initial attack ICs, dispatchers, or other fire personnel during 

pre-season training and planning meetings. 

INTERAGENCY OPERATIONS

Maui County Fire Department (Kahului Station) will provide initial attack response to wildland and 

structural fires on the refuge (Figure 2). If qualified resources are not available, resources will be ordered 

through proper dispatch procedures (Appendix C). The Hawaii Department of Fish and Wildlife 

(DOFAW) would be able to respond to fires in the white areas of the figure below only under specific 

conditions (i.e., extreme threats to public safety, local resources fully committed, extreme fire behavior, 

etc.). In this case, the request for assistance must come from the County Fire Department through the 

County Civil Defense to State Civil Defense. No formal cooperative agreements exist with these agencies. 

 When they are developed, they will be added to Appendix G. 

Keālia Pond will use the Incident Command System (ICS) as a guide for fireline organization. 

Qualifications for individuals are per DOI Wildland Fire Qualifications and Certification System, part of 

NIIMS and the National Wildland Fire Coordination Group (NWCG) Prescribed Fire Qualification Guide. 

Depending on fire complexity, some positions may be filled by the same person. 
12

Kealia Pond NWR

Figure 2. Fire Response Zones for the Island of Maui. 

PROTECTION OF SENSITIVE RESOURCES

Resource advisors will be required for all wildland fires on the refuge. The advisor will work with the 

suppression resources to limit environmental impact. 

The Regional Archaeologist will work with fire staff, Project Leaders, and Incident Commanders to ensure 

that cultural resources are protected from fire and fire management activities. The “Request For Cultural 

Resource Compliance” (RCRC) form (Appendix F) will be used to inform the Regional Archaeologist of 

impending activities, thereby meeting the regulations and directions governing the protection of cultural 

resources as outlined in Departmental Manual Part 519, National Historic Preservation Act (NHPA) of 

1966, Code of Federal Regulations (36CFR800), the Archaeological Resources Protection Act of 1979, as 

amended, and the Archaeological and Historic Preservation Act of 1974. The NHPA Section 106 clearance 

will be followed for any fire management activity that may affect historic properties (cultural resources 

listed or eligible for listing on the National Register of Historic Places). 

Impacts to archaeological resources by fire resources vary. The four basic sources of damage are (1) fire 

intensity, (2) duration of heat, (3) heat penetration into soil, and (4) suppression actions. Of the four, the 

most significant threat is from equipment during line construction for prescribed fires or wildfire holding 

actions (Anderson 1983). 
13

The following actions will be taken to protect archaeological and cultural resources: 

Wildland Fires 

Minimum impact fire suppression tactics will be used to the fullest extent possible. 

The Resource Advisor will inform fire suppression personnel of any areas with cultural resources. 

The Resource Advisor should contact the Regional Archaeologist for more detailed information. 

Foam use will be minimized in areas known to harbor surface artifacts. 

Mechanized equipment should not be used in areas of known cultural significance. 

The location of any sites discovered as the result of fire management activities will be reported to 

the Regional Archaeologist. 

Rehabilitation plans will address cultural resources impacts and will be submitted to the Regional 

Archaeologist using the RCRC. 

Pile Burns 

The refuge fire staff will submit a completed RCRC to the Regional Archaeologist as soon as the 

burn area is identified (i.e., as soon as feasible). 

Upon receipt of the RCRC, the Regional Archaeologist will be responsible for consulting with the 

Zone FMO and evaluating the potential for adverse impacts to cultural resources. 

When necessary, the Regional Archaeologist will coordinate with the State Historic Preservation 

Officer (SHPO). The SHPO has 30 days to respond. The Refuge will consider all SHPO 

recommendations. 

Mechanized equipment should not be used in areas of known cultural significance. 

The location of any sites discovered as the result of fire management activities will be reported to 

the Regional Archaeologist.
14

WILDLAND FIRE SUPPRESSION ACTIVITIES 

Fire program management describes the operational procedures necessary to implement fire management 

at Keālia Pond. Program management includes fire prevention, preparedness, emergency preparedness, 

fire behavior predictions, fire detection, minimum impact fire suppression, minimum impact rehabilitation, 

and documentation. 

All fires not classified as prescribed fires are wildland fires and will be appropriately suppressed. Maui 

County will provide wildland fire suppression resources under most circumstances. Most suppression 

activities will necessitate the use of heavy equipment to create firebreaks or allow the fire to burn to the 

water. 

There is no clearly defined fire season for the refuge and records show that fires may occur at any during 

the year. 

FIRE MANAGEMENT STRATEGIES

Although resource impacts of suppression alternatives must always be considered in selecting a fire 

management strategy, managing fire for resource benefit is not authorized on this refuge. Appropriate 

suppression action will be taken to provide for firefighter safety, public safety, and protection of resources. 

Critical protection areas, including all refuge structures and facilities, will receive priority consideration in 

fire control planning efforts. In all cases, the primary concerns of fire suppression personnel will be safety. 

If needed, all individuals not involved in the suppression effort will be evacuated. 

Suppression strategies should be applied so that the equipment and tools used to meet the desired 

objectives are those that inflict the least impacts upon the natural and cultural resources. Minimum impact 

suppression tactics (MIST) will be employed to protect all resources. Natural and artificial barriers will be 

used as much as possible for containment. When necessary, fire line construction will be conducted in 

such a way as to minimize long-term impacts to resources. Sites impacted by fire suppression activities or 

by the fire will be rehabilitated as necessary, based on an approved course of action for each incident. 

Specific wildland fire management and suppression strategies for Keālia Pond are: 

All wildland fires will be controlled using the appropriate suppression strategy which considers 

safety, property, natural and cultural resources, and economics. 

Mechanical treatment will be used to reduce hazardous fuels around structures and improvements. 

PREPAREDNESS

Preparedness is the work accomplished prior to fire occurrence to ensure that the appropriate response, as 

directed by the Fire Management Plan, can be carried out. Preparedness activities include: budget 

planning, equipment acquisition, equipment maintenance, dispatch (initial attack, extended, and 

expanded), equipment inventory, personnel qualifications, and training. The preparedness objective is to 

have a well trained and equipped fire management organization to manage all fire situations within the 

monument. Preparedness efforts are to be accomplished in the time frames outside the normal fire season 

dates. 

Historical Weather Analysis 

There is no clearly defined fire season for the refuge and records show that fires may occur at any during 

the year. 
15

General fire weather information can be obtained through the National Oceanic and Air Administration 

(NOAA) at fire.boi.noaa.gov. Keālia Pond NWR is located in the area serviced by the National Weather 

Service (NWS) office in Honolulu, Hawaii. The Fire Weather section of the Honolulu NWS website, 

www.prh.noaa.gov/hnl/pages/firewx.php, contains zone maps, fire weather forecasts, and instructions for 

requesting a spot weather forecast. The refuge falls within the Maui Central Valley (019) Fire Weather 

Zone. 

Fire Prevention 

An active fire prevention program will be conducted, as needed, in conjunction with other agencies to 

protect human life and property, and prevent damage to cultural resources or physical facilities. 

A program of internal and external education regarding potential fire danger may be implemented. Visitor 

contacts, bulletin board materials, handouts and interpretive programs can be utilized to increase visitor 

and neighbor awareness of fire hazards. 

During periods of extreme or prolonged fire danger area closures or emergency restrictions regarding 

refuge operations may become necessary. Such restrictions, when imposed, will usually be consistent with 

those implemented by cooperators. 

Hazard Reduction for Structure Protection 

Hazard reduction is conducted to prevent wildland fires from spreading onto structures owned by the FWS 

and adjacent landowners. All vegetation around FWS buildings and storage containers is trimmed to a 

minimum of two feet from the structure. Currently, trimmings are disposed of by way of Maui Disposal to 

the County of Maui’s green waste facility. Non-FWS structures include privately-owned condominiums 

located along the southeast boundary; however, North Kihei Road would provide sufficient protection 

from a wildland fire under most normal circumstances. 

Staffing Priority Levels 

No dedicated fire staff exists on the refuge. If drought conditions require additional fire preparedness and 

funding, addition qualified fire personnel may be assigned to the refuge. 

Training 

Departmental policy requires that all personnel engaged in suppression and prescribed fire duties meet the 

standards set by the National Wildfire Coordinating Group (NWCG), in addition to Service-specific 

standards. Kealiea Pond NWR will conform strictly to the requirements of the wildland fire management 

qualification and certification system and USFWS guidelines. 

Basic wildland fire training refreshers are offered annually for red-carded firefighters through surrounding 

agencies, and records are kept in a centralized database. Additional training is available from surrounding 

agencies in pump and engine operation, power saws, firefighter safety, fire weather and fire behavior, 

helicopter safety and prescribed fire objectives and activities. On-the-job training is encouraged and will 

be conducted at the field level. Whenever appropriate, the use of fire qualification task books will be used 

to document fire experience of trainees. The Zone FMO will coordinate fire training needs with those of 

other nearby refuges, cooperating agencies, and the Regional Office. 

The refuge supports the development of individual Incident Command System (ICS) overhead personnel 

from among qualified and experienced refuge staff for assignment to overhead teams at the local, regional, 

and national level. 
16

Fire suppression is an arduous duty. On pile burns, personnel may be required to shift from 

implementation and/or monitoring activities to suppression. Poor physical condition of crew members can 

endanger safety and lives during critical situations. Personnel performing fire management duties will 

maintain a high level of physical fitness. This requires successful completion of a fitness pack test. 

Personnel must complete a three mile hike with a 45 pound pack in less than 45 minutes. Employees 

participating in any wildland fire activities on Fish and Wildlife Service or cooperators= lands will meet 

fitness requirements established in PMS 310-1, except where Service-specific fitness requirements apply. 

Supplies and Equipment 

Currently, the refuge does not possess any fire equipment or maintain a fire cache. Equipment and 

supplies are available through the interagency cache system. 

DETECTION

Fires are generally reported by the public to the Maui County Fire Department. The Fire Department 

notifies refuge staff of any suppression operations on the refuge. 

COMMUNICATIONS

Currently, refuge communications are limited to telephones (Appendix C). No personnel will be on-site at 

a wildland fire without direct communications with the suppression resources. 

PRE-ATTACK PLAN

Upon discovery of a fire, all subsequent actions will be based on the following: 

The Incident Commander (IC) will locate, size-up, and coordinate suppression actions. The IC 

will complete the pre-attack planning checklist. 

Provide for public safety. 

Considering the current and predicted fire conditions, the Incident Commander will assess the 

need for additional suppression resources and estimate the final size of the fire. The potential for 

spread outside of the refuge should be predicted, as well as the total suppression force required to 

initiate effective containment action at the beginning of each burning period. 

The Incident Commander will assess the need for law enforcement personnel for traffic control, 

investigations, evacuations, etc., and make the request to the FMO. 

Document decisions and complete the fire report (DI-1202). 

Should a wildland fire move into an extended attack a Delegation of Authority will be invoked. 

Once a Delegation of Authority has been authorized the Incident Commander will make the final 

decisions pertaining to the fire. A copy of the Delegation of Authority is in Appendix ?. 

FIRE MANAGEMENT UNITS

Fire Management Units (FMUs) are areas on a refuge which have common wildland fire management 

objectives and strategies, are manageable units from a wildland fire standpoint, and can be based on 

natural or man-made fuel breaks. Keālia Pond NWR will be managed as a single FMU. 

Due to staff limitations, relatively small land management parcels, long response times, valuable resources, 

and values at risk on neighboring lands, this plan does not authorize managing wildland fire for resource 

benefit. Wildland fires will be suppressed using the appropriate suppression response. Pile burning, as a 

limited form of prescribed burning, will be used to reduce hazardous fuels and to meet resource 

management objectives. 
17

FUELS AND FIRE BEHAVIOR

Fuel Types and Fire Behavior 

There are two general fuel types on the refuge. These fuel types correspond to Anderson’s (1982) Fuel 

Models 3 and 6 (Table 2). These types of fuels promote rapid spread and flame heights that may exceed 

20 feet, thus causing control problems. Steady trade winds help promote rapid fire growth. 

Table 2. Habitat types and fuel models on Keālia Pond NWR.

Habitat Type Fuel Model* Acres

Wetlands 1/3 500

Uplands 6 200

Open Water/Roads N/A 200

* NFFL Fuel Model (Anderson 1982)

Fuel Model 3. The 300 acres of wetlands (excluding open water) on the refuge are characteristic of Fuel 

Model 3. Mudflats surrounding the open water are comprised of Pluchea indica and a diversity of 

herbaceous species (Atriplex spp., Sonchus oleraceus, Verbesina encelioides, and Batis martima), grasses 

(Brachiaria mutica, Cenchrus ciliaris, Cynodon dactylon, and Leptochloa uninervia) and sedges 

(Bolboschoenus maritimus and Cyperus laevigatus). Depending on flooding and climatic conditions, the 

vegetation in some areas of this pond may be shorter and more closely resemble Fuel Model 1. In 

September 2001, a prescribed burn in the cane fields passed the fire break and entered the refuge through 

the upland habitat into the mudflats where vegetation (which contained over 90% Batis maritima) burned 

readily and intensely, and displayed a high rate of spread under the influence of wind. Wind may drive fire 

into the upper heights of the vegetation and across small areas of standing water. Table 3 shows predicted 

flame lengths and rates of spread in Fuel Models 1 and 3 under varying conditions from an old burn plan 

for the former Hawaiian Wetlands NWRC. These predictions are only for backing fires, which assumes no 

wind. Wind will cause heading fires and may significantly increase flame lengths and rates of spread for 

these fuel models. 

Fuel Model 6. The refuge’s 200 acres of uplands are covered with dense stands of koa-haole (Leucaena 

leucocephala), kiawe trees (Prosopis pallida), and Indian marsh fleabane (Pluchea indica). Fires carry 

through the shrub layer, but this requires moderate winds. Fire will drop to the ground at low wind speeds 

or at openings in the stand. With winds of 5 miles/hour, dead fuel moisture content of 8%, and live fuel 

moisture content of 100%, predicted flame length is 6 feet, and rate of spread is 32 chains/hour (Anderson 

1982). 
18

Table 3. Backing fire behavior predictions for Keālia Pond NWR in Fuel Models 1 and 3.

Parameter Fuel Model 1 Fuel Model 3

20-ft Windspeed 0-10 mi/hr 0-10 mi/hr

Effective Midflame Windspeed* 0 mi/hr 0 mi/hr

Time of Day 0800 1000 0800 0800 1000 1000

Cloud Canopy Cover (%) Clear Clear Clear Clear Clear Clear

Temperature (°F) 70 90 70 70 90 90

Relative Humidity (%) 65 20 65 65 20 20

Dead Fuel Moisture (%) 12 5 12 13 5 6

Slope (degrees) Flat Flat Flat Flat Flat Flat

Flame Length (ft) 0 1 2 2 3 3

Rate of Spread (ch/hr) 0 5 4 3 5 5

* Backing fire assumes effective mid-flame wind speed = 0. 

Fire Effects 

Fire can promote non-native species, but can be an effective management tool to reduce the density and 

complexity of these species and enhance endangered waterbird habitat. If a wildland fire were to occur on 

the refuge, other than short-term impacts, no negative ecological impacts would be anticipated from either 

suppression methods or the fire itself. A fire during peak Hawaiian stilt or coot nesting could account for 

some nesting failure; however, the benefits to waterbirds of reducing coverage by rank stands of non-native 

species would outweigh any immediate negative effects. 

SUPPRESSION TACTICS

Suppression involves a wide range of possible tactics from the initial attack to final control. To this end, 

all wildland fires will be suppressed in a safe, aggressive, and cost-effective manner to produce efficient 

action with minimal resource damage and limit smoke impacts to local communities. 

Typically, initial attack suppression actions are conducted by the Maui County Fire Department. All fires 

will be assessed by the initial on-scene Incident Commander and attacked using minimum impact fire 

suppression tactics for the Refuge. Roads and natural barriers will be used as much as possible to reduce 

fireline construction. Fireline and mop-up through riparian areas should consider long-term damage to 

vegetation. Unnecessary cutting and bucking should be replaced with alternative actions whenever 

possible. Where wildland fires cross roads, the burned area adjacent to the road should be mopped up and 

dangerous snags felled. 

A Resource Advisor should be assigned to the incident from the beginning to assist with on-the-ground 

tactical decisions and to document rehabilitation needs. There will be only one Incident Commander who 

will be responsible to the Refuge Project Leader. The Incident Commander will designate all overhead 

positions on fires requiring extended attack. Reference should be made to a Delegation of Authority 

(Appendix G). 
19

Suppression Conditions 

A full suppression alternative was selected for this refuge which requires containment and control of all 

wildland fires. Wildland fires will not be managed to achieve resource objectives, although impacts to 

resources may be considered in selecting suppression strategies. Suppression guidelines and restrictions 

(Table 4) were developed for this refuge to protect natural and cultural resources. These guidelines will be 

discussed annually with Maui County Fire Department to ensure their compliance. The Refuge Manager 

should review these guidelines annually and document any changes. 

A Resource Advisor will be used to ensure impacts to natural and cultural resources are minimized. The 

use of heavy, ground-disturbing equipment (including bulldozers) is prohibited for normal fire suppression 

operations. The use of foams and retardants is also prohibited due to the presence of endangered 

waterbirds and extensive wetlands. Off-road travel, firelines constructed with hand tools and/or chainsaws, 

and the use of low-flying aircraft must be approved by the Resource Advisor at all times. Helicopter water 

drops and hose lays from engines must be approved by the Resource Advisor from April through August 

due to the presence of nesting endangered waterbirds; the Incident Commander has approval authority all 

other times. 

Table 4. Keālia Pond NWR Wildland Fire Suppression Guidelines. 

Keālia Pond National Wildlife Refuge – Wildland Fire Suppression Guidelines

NOTE: If human life is threatened, the Incident Commander has the authority to order any suppression 

strategy or tactic available to mitigate the threat.

FIRE MANAGEMENT UNIT – Keālia POND NWR

FMU Description All lands within Keālia Pond National Wildlife Refuge, Maui, Hawaii.

Special Considerations Smoke/fire may cause a health hazard to neighboring communities.

Endangered waterbirds present in wetlands.

Preferred Suppression 

Strategies

Aggressively suppress fire, holding it to the fewest burned acres possible within 

safety constraints, with minimal effect on endangered species and their habitats.

TACTIC MUST BE APPROVED BY:

Hand line/Chainsaws Resource Advisor

Heavy Equipment Prohibited

Off-road Travel Resource Advisor

Hose Lays Resource Advisor (April-August); Incident Commander otherwise

Foam/Retardant Prohibited

Water Drops Resource Advisor (April-August); incident commander otherwise

Helicopters, other AC Resource Advisor

Safety Considerations High rates of fire spread, especially in windy conditions.

Wildland Fire Situation Analysis 

For fires that cannot be contained in one burning period, a Wildland Fire Situation Analysis (WFSA) must 

be prepared. In the case of a wildland fire, the Project Leader, in conjunction with the Zone FMO, will 

prepare the WFSA. Approval of the WFSA resides with the Project Leader. 
20

The purpose of the WFSA is to allow for a consideration of alternatives by which a fire may be controlled. 

Damages from the fire, suppression costs, safety, and the probable character of suppression actions are all 

important considerations. 

Public safety will require coordination between all refuge staff and the IC. Notices should be posted to 

warn visitors, trails may be closed, traffic control will be necessary where smoke crosses roads, etc. Where 

wildland fires cross roads, the burned area adjacent to the road should be mopped up and dangerous snags 

felled. Every attempt will be made to utilize natural and constructed barriers, including changing fuel 

complexes, in the control of wildland fire. Rehabilitation efforts will concentrate on the damages done by 

suppression activities rather than on the burned area itself. 

Aircraft Operations 

Aircraft may be used in all phases of fire management operations. All aircraft must be Office of Aircraft 

Services (OAS) or Forest Service approved. An OAS Aviation Policy Department Manual will be 

provided by OAS. As in all fire management activities, safety is the primary consideration. Qualified 

aviation personnel will be assigned to all flight operations. 

Helicopters may be used for reconnaissance, bucket drops and transportation of personnel and equipment. 

Natural helispots and parking lots are readily available in most cases. Clearing for new helispots should be 

avoided where possible. Improved helispots will be rehabilitated following the fire. 

BURNED AREA EMERGENCY STABILIZATION AND REHABILITATION

There are three methods of repairing damage caused by wildland fires and wildland fire suppression 

activities – emergency stabilization, rehabilitation, and fire suppression activity damage repair. 

Policy and Implementation Guidance 

Departmental policy for emergency stabilization and rehabilitation (ESR) on Service lands following 

wildland fire, including objectives, implementation, plan submittal, monitoring, and funding, is found in 

the Department Manual (620 DM 3). Service ESR supplemental policy can be found in the Service 

Manual (095 FW 3.9), with policy implementation guidance provided in Chapter 5 of the FWS Fire 

Management Handbook. More detailed guidance for can be found in the Interagency Burned Area 

Emergency Stabilization and Rehabilitation Handbook (2002) and Technical Reference (2002). The 

Service maintains an internet web site (http://fire.fws.gov/ifcc/rehab/) that provides access to these and 

several other guidance documents. 

Any treatment or activity will have an approved plan developed prior to implementation. Monitoring 

specifications will be included in the plan for each treatment or activity. Emergency stabilization and 

rehabilitation treatments and activities will be written in separate plans. The Project Leader, Biologist, and 

Zone FMO will review all plans. The final plans will be submitted to the Region for review prior to 

submission to the Washington Office. 

Compliance 

Implementation activities will be conducted in a manner that is compatible with long-term goals and 

approved land management plans (e.g., Comprehensive Conservation Plan, Habitat Management Plan, Fire 

Management Plan), in compliance with applicable law and policy, including the National Environmental 

Policy Act, Endangered Species Act, Clean Water Act, and National Historic Preservation Act. 
21

REQUIRED REPORTING

The IC will be responsible for documenting decisions and completing the fire report (e.g., ICS-214, DI1202). The Zone FMO will be responsible for any additional required reports. 

FIRE INVESTIGATION

Fire management personnel will attempt to locate and protect the probable point of origin and record 

pertinent information required to determine fire cause. They will be alert for possible evidence, protect the 

scene and report findings to the fireline supervisor. 

Prompt and efficient investigation of all suspicious fires will be carried out. However, fire management 

personnel should not question suspects or pursue the fire investigation unless they are currently Law 

Enforcement Commission qualified. 

Personnel and services of other agencies may be utilized to investigate wildland fire arson or fire incidents 

involving structures. All fire investigations should follow the guidelines outlined in the Fire Management 

Handbook (2004). 
22

HAZARD FUEL REDUCTION 

Hazard fuel is vegetation which presents a risk of ignition and sustaining spread of a wildland fire in 

relationship to a threat to some value. Hazard fuel reduction is both a fire prevention activity and a 

wildland fire protection measure. The objectives of this activity are: 

Reduce the hazard risk to service structures and facilities from an approaching wildland fire. 

Reduce the risk of fire spreading to the wildland from a fire originating in a Service owned 

structure or facility. 

Provide defensible space and safety to personnel at those facilities during a wildland fire. 

Meet federal, state and local fire hazard reduction ordinances. 

HAZARD FUEL REDUCTION STRATEGIES

Strategies include mechanical treatment of the hazard fuels and the debris disposal. Mechanical treatment 

is accomplished using normal maintenance procedures. Currently, due to limited staff and equipment 

required to accomplish clearing of large areas, hazard fuel reduction is a result of general habitat 

management activities which consists of mechanical (tractor mower, tracked bobcat, weedwacker) and 

chemical (herbicide) treatments to clear dense areas suitable for waterbird habitat and promote growth of 

non-woody vegetation. A majority of this activity occurs along the north mudflats of the main pond, 

typically during August-October when water level has receded and the areas are accessible by the tractor 

and/or bobcat. The upland areas of the Refuge are not cleared of vegetation for the purpose of hazard fuel 

reduction. Cutting by chainsaw is only performed if truck access is needed. Vegetation along the office 

building is cleared approximately 2 feet from the building. 

Debris must be disposed of to complete the mitigation of the hazard. Debris disposal may be accomplished 

by scattering, chipping or pile burning. The quantity of vegetation, diameter size, crew availability, and 

logistical support will dictate the method used. If scattering of cut vegetation is used, an evaluation of the 

overall fuel loading needs to be considered so as to not add to the hazard fuel problem. 

PILE BURNING GUIDELINES

When planning to dispose of debris by pile burning, specific guidelines must be followed in order to 

provide for safety and reduce the escape potential. General guidelines for pile burning are the same as for 

prescribed burning. Service guidelines are found in the FWS Fire Management Handbook, Section 2. 

This section of the Fire Management Plan is for the purpose of outlining the steps to take when conducting 

pile burning only. No prescribed burning of standing vegetation will be conducted. References to a burn 

plan and burn boss are only for the purpose of pile burning. 

Pile burning will be used to dispose of cut vegetation resulting from refuge activities such as annual hazard 

reduction around structures. Limbs and branches of overhanging trees and brush will annually need to be 

trimmed back. At times trees may have been blown down during storms which will require debris 

removal. The most economical and expedient method is through burning of the piled vegetation on site. 

Pile burning is typically rated as complexity level 3 due to the low risk of escape, limited control forces, 

and time of year conducted. Safety concerns are still present even at the low complexity level. Careful 

consideration must be given to smoke management, escape potential and resource benefit when planning 

and rating the pile burn. The complexity of each pile burn would be evaluated using the NWCG 

Prescribed Fire Complexity Rating System Guide. 
23

Pile Burn Plan 

A Burn Boss will conduct a field reconnaissance of the proposed pile burn location with the Refuge 

Manager to discuss objectives, special concerns, and gather all necessary information to write the burn 

plan. After completing the reconnaissance, a qualified Burn Boss will write the Pile Burn Plan. 

All pile burning will have a Pile Burn Plan. The Pile Burn Plan is a site-specific action plan describing the 

purpose, objectives, prescription, and operational procedures needed to prepare and safely conduct the 

burn. The project area, objectives, and constraints will be clearly outlined. No piles will be ignited unless 

all prescriptions of the plan are met. Fires not within those parameters will be suppressed. Pile Burn Plans 

will follow the format found in the FWS Fire Management Handbook, Section 2.2. Pile burning is 

considered a complexity level 3 prescribed burn (in most cases) and should use the plan format contained 

in Appendix C. Each burn plan will be reviewed by the Project Leader, Refuge Manager, Refuge 

Biologist, Zone FMO, and Burn Boss. The Project Leader has the authority to approve the burn plan. 

The Pile Burn Plan requires the following items to be completed prior to ignition: 

Contingency plan 

Complexity analysis 

Review and approval signatures 

Go/no go checklist 

Spot weather forecast 

Pile Burning Strategies and Personnel 

Pile burning will only be executed by qualified personnel. Pile burning requires a qualified Burn Boss. 

The Burn Boss will fill all required positions to conduct the burn with qualified personnel. All positions 

listed in the burn plan must be available for the duration of the pile burn or it will not be initiated. 

Weather and fuel moisture conditions must be monitored closely in the project area to determine when the 

prescription criteria are met. A belt weather kit may also be utilized to augment monitoring. 

When pertinent prescription criteria are within the acceptable range, the Burn Boss will select an ignition 

time based on current and predicted weather forecasts. A thorough briefing will be given by the Burn Boss 

on the day of the burn and specific assignments and placement of personnel will be discussed. An updated 

spot weather forecast will be obtained on the day of ignition and all prescription elements will be rechecked to determine if all elements are still within the approved ranges. If all prescription elements are 

met, a test fire will be ignited to determine on-site fire behavior conditions as affected by current weather. 

If conditions are not satisfactory, the test fire will be suppressed and the burn will be rescheduled. If 

conditions are satisfactory, the burn will continue as planned. 

Maui County Fire Department will be made aware of any planned burn. If the burn pile escapes the 

predetermined burn area, all further ignition will be halted except as needed for suppression efforts. 

Suppression efforts will be initiated, as discussed in the pre-burn briefing. The Zone FMO will be notified 

immediately of any control actions on a prescribed burn. If the burn exceeds the initial suppression efforts, 

the burn will be declared a wildland fire and suppressed using guidelines established in the burn plan. A 

WFSA will be completed and additional personnel and resources ordered as determined by the Incident 

Commander. If the fire continues to burn out of control, additional resources based on the contingency 

plan will be called from the local cooperating agencies via the servicing dispatch. A management 

overhead team may be requested to assume command of the fire if necessary. Each Pile Burn Plan will 

detail the contingency plan with identified resources for suppression. This plan will serve as the incident 

action plan during the initial attack phase of an escape. 
24

Monitoring and Evaluation 

During pile burns, monitoring can serve as a precursor to invoking suppression action by determining if the 

burn is in prescription, assessing its overall potential, and determining the effects of the pile burn. Pile 

burning does not usually require extensive monitoring. Weather, fire behavior, and smoke management 

are elements that require monitoring. The Burn Boss will assume responsibility for coordinating and 

implementing this section. Personnel may be assigned specific tasks such as weather monitoring to 

document these elements and keep the Burn Boss informed of conditions. Special situations or projects 

may dictate more extensive monitoring and evaluation. 

Required Reports 

All forms will be completed as outlined by the Pile Burn Plan. Accomplishments, costs, fire report (DI1202), weather data, and first order fire effects monitoring are the responsibility of the Burn Boss. The 

Burn Boss may prepare a final report on the project for the Refuge Manager as requested. Information 

should include a narrative of the burn operation, a determination of whether objectives were met, weather 

and fire behavior data, number of work hours, and final cost of the burn. 
25

AIR QUALITY / SMOKE MANAGEMENT GUIDELINES 

An annual burn permit is required by the State of Hawaii, Department of Health for each prescribed burn. 

This permit process evaluates the burn in relation to emissions and local air quality standards. Typically, 

smoke from fires does not significantly affect air quality standards. The Refuge is required to report the 

schedule of each burn to the Department of Health and is also required to follow permit conditions 

provided by the Department of Health that are designed to minimize effects on air quality. These 

conditions include a specified time period when burns are permitted and attention to not burning on 

specified “no-burn” days for specified islands as provided on or before 1600 hr by radio broadcast through 

the National Weather Service, or other appropriate means, applicable for the succeeding day. The State of 

Hawaii, Department of Health, Agricultural Burn Permit along with an approved Prescribed Burn Plan for 

the refuge are maintained in the Refuge Complex office. The Agricultural Burn Permit must be renewed 

annually and in possession at the burn site while burning. 

FIRE RESEARCH 

There are no ongoing fire research projects at Keālia Pond NWR. 
26

PUBLIC SAFETY 

Keālia Pond is dedicated to ensuring the safety of each visitor and to all residents and property adjacent to 

the refuge's boundary. The refuge will be closed to the public during suppression and possibly during pile 

burn activities. 

Areas of fire activity may be clearly signed at the refuge entrance gate. Residents adjacent to the refuge 

(Appendix C, Table 3) will be notified in advance of any pile burn and if any fire poses a threat to burn 

outside the refuge boundaries. 

During pile burns at least one burn team member will have first aid training. A first aid kit will be on-site 

for prescribed burns as well as wildland fires. The local police, fire, and emergency medical services will 

be notified prior to the ignition. They will also be notified of the location of any wildland fires. 

PUBLIC INFORMATION AND EDUCATION

Educating the public on the value of fire as a natural process is important to increasing public 

understanding and support for the fire management program. The refuge will use the most appropriate and 

effective means to explain the overall fire and smoke management program. This may include 

supplemental handouts, signing, personal contacts, auto tour routes, or media releases. When deemed 

necessary, interpretive presentations will address the fire management program and explain the role of fire 

in the environment. 

The public information program will be developed as follows: 

The fire management program may be incorporated into visitor contacts. Particular attention will 

be given when fires are conspicuous from roads or visitor use areas. 

News releases will be distributed to the media as appropriate. 

The public information outlets of neighboring and cooperating agencies and the regional office 

will be provided with all fire management information. 

The fire management program will be discussed in informal talks with all employees , volunteers, 

residents, and neighbors. 

As outlined in the prevention section, emergency closures or restrictions may become necessary during 

periods of extreme or extended fire danger. 
27

FIRE CRITIQUES AND ANNUAL PLAN REVIEW 

FIRE CRITIQUES

Fire reviews will be documented and filed with the final fire report. The Refuge Manager will retain a 

copy for the refuge files. 

ANNUAL FIRE SUMMARY REPORT

The Refuge Manager will be responsible for completing an annual fire summary report. The report will 

contain the number of fires by type, acres burned by fuel type, cost summary (pile burns and wildland 

fires), personnel utilized, and fire effects. 

ANNUAL FIRE MANAGEMENT PLAN REVIEW

The Fire Management Plan will be reviewed annually. Necessary updates or changes will be accomplished 

prior to the next fire season. Any additions, deletions, or changes will be reviewed by the Project Leader 

to determine if such alterations warrant a re-approval of the plan. 

CONSULTATION AND COORDINATION 

The following agencies, organizations and/or individuals were consulted in preparing this plan. 

Bruce Babb, Wildland/Urban Interface Coordinator, Pacific Region, USFWS, Portland, OR. 

Forrest Cameron, Refuge Supervisor, USFWS, Portland, OR. 

Jerry Leinecke, Project Leader, Hawaii/Pacific Islands NWR Complex, Honolulu, HI. 

Amanda McAdams, (former) Fire Ecologist, Pacific Region, USFWS, Portland, OR. 

Mike Nishimoto, Wildlife Biologist, Maui NWR Complex, Kihei, HI. 

James Roberts, Fire Planner, Pacific Region, USFWS, Portland, OR. 

Linda Watters, Assistant Refuge Supervisor, USFWS, Portland, OR. 
28

APPENDICES 

APPENDIX A: REFERENCES CITED

Anderson, B.A. 1983. Archaeological considerations for park and wilderness fire management planning. 

Paper presented at Wilderness Fire Symposium at the University of Montana, Missoula. 

Unpublished. 13pp. 

Anderson, H.A. 1982. Aids to determining fuel models for estimating fire behavior. USDA For. Serv. 

Gen. Tech. Rep. INT-122, 22p. Intermt. For. and Range Exp. Stn., Ogden, Utah 84401. 

Armstrong, R.W. and J.A. Bier. 1983. Atlas of Hawaii. Second Edition. University of Hawaii Press. 

Honolulu, Hawaii. 

National Wildfire Coordinating Group. 1996. Resource advisor=s guide for wildland fire. PMS 313/ 

NFES 1831. 

Pratt, H.D., P.L. Bruner, and D.G. Berrett. 1987. The Birds of Hawaii and the Tropical Pacific. Princeton 

University Press, Princeton, New Jersey. 

Soil Conservation Service. 1973. Soil Survey of Island of Hawaii, State of Hawaii. U.S. Department of 

Agriculture in cooperation with University of Hawaii. U.S. Government Printing Office, 

Washington, DC. 

U.S. Department of the Interior. 1997 Department Manual. Washington D.C. 

U.S. Fish and Wildlife Service. 1981. Keālia Pond National Wildlife Refuge: Final Environmental 

Assessment. U.S. Department of the Interior. Honolulu, Hawaii. 

U.S. Fish and Wildlife Service. 2001. Keālia Pond NWR Management Plan. U.S. Department of the 

Interior. Honolulu, Hawaii. 
29

APPENDIX B: DEFINITIONS

Agency Administrator. The appropriate level manager having organizational responsibility for 

management of an administrative unit. May include Director, State Director, District Manager or Field 

Manager (BLM); Director, Regional Director, Complex Manager or Project Leader (FWS); Director, 

Regional Director, Park Superintendent, or Unit Manager (NPS), or Director, Office of Trust 

Responsibility, Area Director, or Superintendent (BIA). 

Appropriate Management Action. Specific actions taken to implement a management strategy. 

Appropriate Management Response. Specific actions taken in response to a wildland fire to implement 

protection and fire use objectives. 

Appropriate Management Strategy. A plan or direction selected by an agency administrator which 

guides wildland fire management actions intended to meet protection and fire use objectives. 

Appropriate Suppression. Selecting and implementing a prudent suppression option to avoid 

unacceptable impacts and provide for cost-effective action. 

Bureau. Bureaus, offices or services of the Department. 

Class of Fire (as to size of wildland fires). 

Class A - 3 acre or less. 

Class B - more than 3 but less than 10 acres. 

Class C - 10 acres to 100 acres. 

Class D - 100 to 300 acres. 

Class E - 300 to 1,000 acres. 

Class F - 1,000 to 5,000 acres. 

Class G - 5,000 acres or more. 

Emergency Fire Rehabilitation/Burned Area Emergency Rehabilitation (EFR/BAER). Emergency 

actions taken during or after wildland fire to stabilize and prevent unacceptable resource degradation or to 

minimize threats to life or property resulting from the fire. The scope of EFR/BAER projects are 

unplanned and unpredictable requiring funding on short notice. 

Energy Release Component (ERC). A number related to the available energy (BTU) per unit area 

(square foot) within the flaming front at the head of a fire. It is generated by the National Fire Danger 

Rating System, a computer model of fire weather and its effect on fuels. The ERC incorporates thousand 

hour dead fuel moistures and live fuel moistures; day to day variations are caused by changes in the 

moisture content of the various fuel classes. The ERC is derived from predictions of (1) the rate of heat 

release per unit area during flaming combustion and (2) the duration of flaming. 

Extended Attack. A fire on which initial attack forces are reinforced by additional forces. 

Fire Suppression Activity Damage. The damage to lands, resources and facilities directly attributable to 

the fire suppression effort or activities, including: dozer lines, camps and staging areas, facilities (fences, 

buildings, bridges, etc.), handlines, and roads. 

Fire Effects. Any consequences to the vegetation or the environment resulting from fire, whether neutral, 

detrimental, or beneficial. 
30

Fire Intensity. The amount of heat produced by a fire. Usually compared by reference to the length of the 

flames. 

Fire Management. All activities related to the prudent management of people and equipment to prevent 

or suppress wildland fire and to use fire under prescribed conditions to achieve land and resource 

management objectives. 

Fire Management Plan. A strategic plan that defines a program to manage wildland and prescribed fires 

and documents the Fire Management Program in the approved land use plan. The plan is supplemented by 

operational procedures such as preparedness plans, preplanned dispatch plans, prescribed fire plans and 

prevention plans. 

Fire Prescription. A written direction for the use of fire to treat a specific piece of land, including limits 

and conditions of temperature, humidity, wind direction and speed, fuel moisture, soil moisture, etc., under 

which a fire will be allowed to burn, generally expressed as acceptable range of the various fire-related 

indices, and the limit of the area to be burned. 

Fuels. Materials that are burned in a fire; primarily grass, surface litter, duff, logs, stumps, brush, foliage, 

and live trees. 

Fuel Loadings. Amount of burnable fuel on a site, usually given as tons/acre. 

Hazard Fuels. Those vegetative fuels which, when ignited, threaten public safety, structures and 

facilities, cultural resources, natural resources, natural processes, or to permit the spread of wildland fires 

across administrative boundaries except as authorized by agreement. 

Initial Attack. An aggressive suppression action consistent with firefighter and public safety and values 

to be protected. 

Maintenance Burn. A fire set by agency personnel to remove debris; i.e., leaves from drainage ditches or 

cuttings from tree pruning. Such a fire does not have a resource management objective. 

Natural Fire. A fire of natural origin, caused by lightning or volcanic activity. 

NFDRS Fuel Model. One of 20 mathematical models used by the National Fire Danger Rating System to 

predict fire danger. The models were developed by the U.S. Forest Service and are general in nature 

rather than site-specific. 

NFFL Fuel Model. One of 13 mathematical models used to predict fire behavior within the conditions of 

their validity. The models were developed by US Forest Service personnel at the Northern Forest Fire 

Laboratory, Missoula, Montana. 

Prescription. Measurable criteria which guide selection of appropriate management response and actions. 

Prescription criteria may include safety, public health, environmental, geographic, administrative, social, or 

legal considerations. 

Prescribed Fire. A fire ignited by agency personnel in accord with an approved plan and under 

prescribed conditions, designed to achieve measurable resource management objectives. Such a fire is 

designed to produce the intensities and rates of spread needed to achieve one or more planned benefits to 
31

natural resources as defined in objectives. Its purpose is to employ fire scientifically to realize maximize 

net benefits at minimum impact and acceptable cost. A written, approved prescribed fire plan must exist 

and NEPA requirements must be met prior to ignition. NEPA requirements can be met at the land use or 

fire management planning level. 

Preparedness. Actions taken seasonally in preparation to suppress wildland fires, consisting of hiring and 

training personnel, making ready vehicles, equipment, and facilities, acquiring supplies, and updating 

agreements and contracts. 

Prevention. Activities directed at reducing the number or the intensity of fires that occur, primarily by 

reducing the risk of human-caused fires. 

Rehabilitation. Actions to (1) limit the adverse effects of suppression on soils, watershed, or other values, 

or (2) to mitigate adverse effects of a wildland fire on the vegetation-soil complex, watershed, and other 

damages. 

Suppression. A management action intended to protect identified values from a fire, extinguish a fire, or 

alter a fire's direction of spread. 

Unplanned Ignition. A natural fire that is permitted to burn under specific conditions, in certain 

locations, to achieve defined resource objectives. 

Wildfire. An unwanted wildland fire. 

Wildland Fire. Any non-structure fire, other than prescribed fire, that occurs in the wildland. 

Wildland Fire Situation Analysis (WFSA). A decision-making process that evaluates alternative 

management strategies against selected safety, environmental, social, economical, political, and resource 

management objectives as selection criteria. 

Wildland/Urban Interface Fire. A wildland fire that threatens or involves structures. 
32

APPENDIX C: FIRE DISPATCH PLAN

2004 Fire Dispatch Plan 

Keālia Pond National Wildlife Refuge 

FIRE SIZE-UP 

 

Use the following or the card, pocket guide, fireline handbook or red book guides. 

Reporting party’s name and phone number: 

Time discovered: 

Location of smoke or fire (plot on map; legal description): 

Fire Behavior: Smoldering Creeping Running Crowning Spotting 

Estimated size (acres): Spot 1/4-1/2 1/2-3/4 1 1-5 5+

Wind (midflame speed & direction): 

Dry Bulb Temperature (°F): Relative Humidity (%): 

Fuel Type: Grass Brush Timber Slash 

Adjacent Fuels: Grass Brush Timber Slash 

Aspect: Percent Slope: 

Additional Resources Needed: 

Special Considerations: 
33

NOTIFICATION

Upon report of a wildland fire, follow these procedures: 

1. Call Maui County Fire Department (911) – request response, ambulance if necessary, traffic 

control. 

2. Notify Refuge Manager/Resource Advisor, Glynnis Nakai, at the Refuge Office (808-875-1582), 

residence (808-878-3269), or cell phone (808-281-9698). Assignments will be made at this time 

to notify other personnel and agencies. 

3. Notify other Refuge personnel at the Refuge Office (808-875-1582) or at their residence: 

 Mike Nishimoto, Wildlife Biologist/Resource Advisor Residence: (808) 873-9315

 Cell: (808) 870-6461

Calvin Willis, Maintenance Worker Residence: (808) 873-0070

 Cell: (808) 870-6450

 Pat Savino, Admin. Support Asst. Residence: (808) 878-2880

4. Notify Project Leader, Jerry Leinecke, at the Hawaiian and Pacific Islands NWRC Office in 

Honolulu (808-792-9540) or at his residence (808-395-6227). 

5. Contact one of the following Regional FWS Duty Officers: 

 Pam Ensley – Regional Fire Management Coordinator Work: (503) 231-6174

 Cell: (503) 781-7978

 Home: (360) 835-7004

 Roger Spaulding – Regional Fire Management Officer Work: (503) 231-6175

 Cell: (503) 816-7054

 (vacant) – Regional Prescribed Fire Specialist Work: (503) 231-2075

 Cell: 

 Bruce Babb – Fire Management Specialist/Regional WUI Coordinator Work: (503) 231-6234

 Cell: (503) 703-5823
34

ESTABLISHED SUPPRESSION GUIDELINES

A full suppression alternative was selected for this refuge which requires containment and control of all 

wildland fires. Wildland fires will not be managed to achieve resource objectives, although impacts to 

resources may be considered in selecting suppression strategies. Suppression guidelines and restrictions 

(Table 4) were developed for this refuge to protect natural and cultural resources. These guidelines will be 

discussed annually with Maui County Fire Department to ensure their compliance. The Refuge Manager 

should review these guidelines annually and document any changes. 

A Resource Advisor will be used to ensure impacts to natural and cultural resources are minimized. The 

use of heavy, ground-disturbing equipment (including bulldozers) is prohibited for normal fire suppression 

operations. The use of foams and retardants is also prohibited due to the presence of endangered 

waterbirds and extensive wetlands. Off-road travel, firelines constructed with hand tools and/or chainsaws, 

and the use of low-flying aircraft must be approved by the Resource Advisor at all times. Helicopter water 

drops and hose lays from engines must be approved by the Resource Advisor from April through August 

due to the presence of nesting endangered waterbirds; the Incident Commander has approval authority all 

other times. 

Keālia Pond National Wildlife Refuge – Wildland Fire Suppression Guidelines

NOTE: If human life is threatened, the Incident Commander has the authority to order any suppression 

strategy or tactic available to mitigate the threat.

FIRE MANAGEMENT UNIT – Keālia POND NWR

FMU Description All lands within Keālia Pond National Wildlife Refuge, Maui, Hawaii.

Special Considerations Smoke/fire may cause a health hazard to neighboring communities.

Endangered waterbirds present in wetlands.

Preferred Suppression 

Strategies

Aggressively suppress fire, holding it to the fewest burned acres possible within 

safety constraints, with minimal effect on endangered species and their habitats.

TACTIC MUST BE APPROVED BY:

Hand line/Chainsaws Resource Advisor

Heavy Equipment Prohibited

Off-road Travel Resource Advisor

Hose Lays Resource Advisor (April-August); Incident Commander otherwise

Foam/Retardant Prohibited

Water Drops Resource Advisor (April-August); incident commander otherwise

Helicopters, other AC Resource Advisor

Safety Considerations High rates of fire spread, especially in windy conditions.

COMMUNICATIONS

Currently, refuge communications are limited to telephones. No personnel will be on-site at a wildland fire 

without direct communications with the suppression resources. 
35

CONTACT LIST

Table 5. Maui National Wildlife Refuge Complex Staff.

Maui NWRC P.O. Box 1042

(Mile 6 Mokulele Hwy.)

Kihei, HI 96753

Phone: (808) 875-1582

Fax: (808) 875-2945

Glynnis Nakai

Refuge Complex Manager

95 Mano Drive

Kula, HI 96790

Work: (808) 792-9548

Cell: (808) 753-0627

Home: (808) 395-6227

Michael Nishimoto

Wildlife Biologist

Kihei, HI Work: (808) 875-1582

Cell: (808) 870-6461

Home: (808) 873-9315

Calvin Willis

Maintenance Worker 

Kihei, HI Work: (541) 867-4550

Cell: (808) 870-6450

Home:

Patricia Savino

Administrative Officer

Kihei, HI Work: (808) 875-1582

Home: (808) 878-2880

Nicole Davis

Biological Science Technician

Kihei, HI Work: (808) 875-7258

Cell: (808) 870-6457

Home: (808) 875-0099

ADJACENT LANDOWNERS 

Table 6. Landowners adjacent to Keālia Pond NWR.

Landowner Address Phone Number

Alexander & Baldwin Properties, Inc. 33 Lono Ave., Ste. 400, Kahului, HI 96732 (808) 872-4313

Hawaiian Commercial & Sugar Co. P.O. Box 266, Puunene, HI 96784 (808) 877-6968

Maui Humane Society Mokulele Highway, Kihei, HI 96753 (808) 877-3680

Maui Electric Company 210 W. Kaahumanu Ave., Kahului, HI 96732 (808) 876-1325

Puanani o Kula Nursery Mokulele Hwy., Kihei, HI 96753 (808) 879-7777

Keālia Resort 191 N. Kihei Rd., Kihei, HI 96753 (808) 879-0952

Sugar Beach Resort 145 N. Kihei Rd., Kihei, HI 96753 (808) 879-7765

Kihei Sands 115 N. Kihei Rd., Kihei, HI 96753 (808) 879-2624

Nani Kai Hale 73 N. Kihei Rd., Kihei, HI 96753 (808) 875-0630

Kihei Kai Resort 61 N. Kihei Rd., Kihei, HI 96753 (808) 891-0780

Maalaea Surf 12 S. Kihei Rd., Kihei, HI 96753 (808) 879-0507
36

APPENDIX D: NEPA COMPLIANCE

UNITED STATES FISH AND WILDLIFE SERVICE

ENVIRONMENTAL ACTION STATEMENT FOR CATEGORICAL EXCLUSION

Within the spirit and intent of the Council on Environmental Quality's regulations for implementing the 

National Environmental Policy Act of 1969 (NEPA), and other statutes, orders, and policies that protect 

fish and wildlife resources, I have established the following administrative record and determined that the 

action of: 

Implementation of the 2004 Wildland Fire Management Plan for Keālia Pond National Wildlife 

Refuge, which includes guidance for wildland fire suppression, hazard fuel reduction, and pile 

burning as a limited form of prescribed fire

Check One: 

 X Is a categorical exclusion as provided by 516 DM 6, Appendix 1.4. No further NEPA 

documentation will be made. 

 Is found not to have significant environmental effects as determined by the attached 

Environmental Assessment and Finding of No Significant Impact. 

 Is found to have significant effects and, therefore, further consideration of this action will require a 

notice intent to be published in the Federal Register announcing the decision to prepare an 

environmental impact statement. 

 Is not approved because of unacceptable environmental damage, or violation of Fish and Wildlife 

Service mandates, regulations, or procedures. 

 Is an emergency action within the context of 40 CFR 1506.11. Only those actions necessary to 

control the immediate impacts of the emergency will be taken. Other related actions remain 

subject to NEPA review. 

Proposed Action and Alternatives: Use of prescribed fire to reduce fuels, restore the natural processes 

and vitality of ecosystems, improve wildlife habitat, remove or reduce non-native species and noxious 

weeds, and/or conduct research. 

Categorical Exclusions: The specific categorical exclusions from NEPA allowing for this action pursuant 

to 516 DM 6, Appendix 1.4 are: 

B.(4) The use of prescribed burning for habitat improvement purposes, when conducted in 

accordance with departmental and Service procedures. 

B.(5) Fire management activities, including prevention and restoration measures, when 

conducted in accordance with departmental and Service procedures. 

Permits/Approvals: The Wildland Fire Management Plan for Keālia Pond National Wildlife Refuge 

must be approved by the Refuge Manager, Project Leader, Regional Fire Management, and Regional 

Director. All prescribed fire projects require a burn plan approved by the Project Leader. 
37 

Public Involvement/Interagency Coordination: Maui County Fire Department Kahului Station is 

notified prior to any prescribed burning. 

Supporting Documents: 

2004 Wildland Fire Management Plan for Keālia Pond National Wildlife Refuge. 

ESA Section 7 Biological Evaluation for pile and debris burning for refuges within the Maui 

National Wildlife Refuge Complex (Keālia Pond NWR and Kakahaia NWR) (Appendix E of this 

FMP). 

Signature Approval: 

 

Jerry Leinecke, Project Leader Date 

Hawaiian and Pacific Islands National Wildlife Refuge Complex 
38

APPENDIX E: ESA SECTION 7 COMPLIANCE

INTRA-SERVICE SECTION 7 BIOLOGICAL EVALUATION 

Pile and Debris Burning for refuges within the Maui National Wildlife Refuge Complex 

(Keālia Pond NWR and Kakahaia NWR) 

 Originating Person: Glynnis Nakai 

 Telephone Number: (808) 875-1582 

 Date: July 13, 2003 

I. Region: Pacific (Region 1), Portland Oregon. 

II. Service Activity:

Pile and debris burning as a marsh vegetation management technique at Keālia Pond National 

Wildlife Refuge on Maui and Kakahaia National Wildlife Refuge on Molokai. 

III. Pertinent Species and Habitat: 

A. Listed species and/or their critical habitat within the action area: 

 Hawaiian coot (Fulica alai) – Endangered 

 Hawaiian stilt (Himantopus mexicanus knudseni) – Endangered 

B. Proposed species and/or proposed critical habitat within the action area: NONE 

C. Candidate species within the action area: NONE 

IV. Geographic area or station name and action:

Refuges of this Complex are located in the state of Hawaii, County of Maui: Keālia Pond NWR on 

the island of Maui and Kakahaia NWR on the island of Molokai. 

Pile and debris burning to control and remove non-native vegetation in wetland marsh and 

mudflats. 

V. Location (attach map):

A. County and State: Maui County, State of Hawai’i 

B. Distance (miles) and direction to nearest town: 

 Ma’alaea is 1.5 miles southwest of Keālia Pond NWR 

 Kaunakakai is approximately 5.5 miles northeast of Kakahaia NWR. 
39

VI. Action Objectives:

Pile and debris burning will be conducted on these wetland refuges as a means of controlling 

noxious and exotic vegetation that interferes with nesting and maintenance of endangered and 

migratory waterbirds. Control of the establishment and spread of these species is required to 

provide secure, viable, adequate habitat for endangered waterbirds, migratory waterfowl and 

shorebirds. Specific goals include: providing open water areas interspersed with escape, nesting, 

and maintenance cover; limiting predator cover and access; providing mudflat areas for nesting 

(Hawaiian stilts) and feeding; and promotion of desirable wetland plant species with water areas for 

Hawaiian coot nesting and maintenance. 

VII. Explanation of Impacts of Action:

This action will result in enhanced wetlands for endangered and other species using the refuge. 

Undesirable plant species will be controlled encouraging growth of more beneficial species. Dense 

predator concealment cover will be reduced making it more difficult for predators to prey on 

endangered species and allow waterbirds to detect predators at a greater distance, reducing 

predation. Increased habitat for a diversity of species, both resident and migratory, will be made 

available. The ratio of open water to vegetation will be altered to provide additional habitat 

diversity within the wetlands. 

All burns will be conducted outside major endangered species nesting seasons. Burns will normally 

be conducted between August and October. Burns will not be initiated when pre-fledgling birds are 

present. A check of each burn site will be made to determine the presence of waterbirds, young, 

and/or nests. If any of the above are discovered, no burning in that area of the wetlands will be 

undertaken. To provide necessary foraging habitat while burning, not all areas will be drawn down 

or dry at the same time. Wetland habitat on the refuge will continue to be provided for endangered 

and other waterbirds to utilize until worked ponds are re-flooded. 
40

VIII. Effect determination and response requested: [* = optional]

A. Listed species/designated critical habitat: 

Determination Response requested 

No effect/no adverse modification ____*Concurrence 

May affect, but is not likely to adversely affect species/adversely X Concurrence 

modify critical habitat 

 Hawaiian coot (Fulica alai) – Endangered 

 Hawaiian stilt (Himantopus mexicanus knudseni) – Endangered 

May affect, and is likely to adversely affect species/adversely modify ____Formal Consultation 

critical habitat 

B. Proposed species/proposed critical habitat: NONE

C. Candidate species: NONE

IX. Signature 

 

 Glynnis Nakai, Refuge Manager Date 

 Maui National Wildlife Refuge Complex 

X. Reviewing ESO Evaluation: 

A. Concurrence Nonconcurrence 

 

B. Formal consultation required 

C. Conference required 

D. Informal conference required 

 E. Remarks (attach additional pages as needed): 

 

 Field Supervisor Date 

 Ecological Services, Pacific Islands Field Office 
41

APPENDIX F: REQUEST FOR CULTURAL RESOURCE COMPLIANCE

REQUEST FOR CULTURAL RESOURCE COMPLIANCE

Project Name: 

USFWS Unit: 

Org Code: 

Ecoregion: 

(By ARD; CBE, IPE, KCE, NCE) 

Program: 

(Partners, WSECP, Refuges, Hatcheries, Jobs, Federal Aid, Other) 

Location: County: State: 

(nearest town) 

Township(s): Range(s): Section(s): Meridian: 

7.5’ USGS Quad(s): 

(Name, Date) 

Project acres or linear meters/feet: 

Date you want to start the project: Date of this request: 

USFWS Contact: Phone: 

Address: Fax: 

Directions to project (if not obvious): 

Attach to this form: 

A project (sketch) map showing the Area of Potential Effect with locations of specific ground altering activities (required). 

A photocopy of the USGS quad clearly marking the project area (required). 

A photocopy of an air photo showing the project may be attached (if available). 

Return form and direct questions to: 

USFWS Region 1 Cultural Resources Team 

c/o Tualatin River NWR 

20555 SW Gerda Lane 

Sherwood, OR 97140 

Phone: (503) 625-4377

Fax: (503) 625-4887

NHPA COMPLIANCE

 Appendix Item 

of the Programmatic Agreement applies.

 36CFR800.4 to 800.6 applies.

Cultural Resources Team Date
42

The Undertaking: Describe the proposed project and means to facilitate it (e.g., provide funds to revegetate 1 mile of riparian habitat, 

restore 250 acres of seasonal wetlands, and construct a 5-acre permanent pond). How is the project designed (e.g., install 2 miles of fence and 

create approximately 25 feet of 3 foot high check dam)? 

Area of Potential Effect: Describe where disturbance of the ground will occur. What are the dimensions of the area to be 

disturbed? How deep will you excavate? How long is the ditch, fence, etc? Where will fill be obtained? Where will spoil be dumped? 

What tools or equipment will be used? Are you replacing or repairing a structure? Are you moving dirt in a relatively undisturbed area? 

 Will the project reach below or beyond the limits of prior land disturbance? Differentiate between areas slated for earth movement 

versus areas to be inundated only. Is the area to be inundated different from the area inundated today, in the recent past, or under 

natural conditions? Provide acres and/or linear meters or feet for all elements of the undertaking.

Environmental Setting: Describe the environmental setting of the Area of Potential Effect. A) What was the natural habitat 

prior to modifications, reclamation, agriculture, settlement? B) What is the land-use history? When was it first settled, modified? How 

deep has it been cultivated? Grazed? etc. C) What is the land-use and habitat today? What natural agents (e.g., sedimentation, or 

vegetation) or cultural agents (e.g., cultivation) might affect the ability to discover cultural resources? D) Do you (or does anybody else) 

know of cultural resources in or near the project area?
43

APPENDIX G: INTERAGENCY AGREEMENTS

No interagency agreements have been developed. When completed, they will be added here. 
44

APPENDIX H: PILE BURN PLAN TEMPLATE

REFUGE OR STATION: UNIT:

Prepared By:

Prescribed Fire Specialist Date

Reviewed By:

Refuge Biologist Date

Reviewed By:

Prescribed Fire Burn Boss Date

Reviewed By:

Fire Management Officer Date

Reviewed By:

Biological Investigation Unit Date

Reviewed By:

Refuge Manager Date

The approved Pile Burn Plan constitutes the authority to burn, pending approval of Section 7 

Consultations, Environmental Assessments or other required documents. No one has the authority to 

burn without an approved plan or in a manner not in compliance with the approved plan. Pile burning 

conditions established in the plan are firm limits. Actions taken in compliance with the approved Pile 

Burn Plan will be fully supported, but personnel will be held accountable for actions taken which are 

not in compliance with the approved plan.

Approved By:

Project Leader Date
45

PILE BURN PLAN 

Note: This plan is intended for burning debris and piles (activity fuels) from refuge operations such 

as fuel break construction and hazard reduction. This plan format should only be used outside of 

declared fire season for the area considered. THIS PLAN IS FOR COMPLEXITY LEVEL 3 PILE 

BURNING. 

Refuge: Refuge Burn Number:

Substation: Fire Number:

Name of Area: Unit Number:

Legal Description: T R S Meridian:

Latitude: Longitude:

County: State:

Checklist: 

1. EA optional. 

2. Resource objectives. 

3. Less than 1 ton per pile, completely dried. 

4. Has minimum resources (equipment & personnel) required. 

5. Has weather parameters been established 

6. Low potential for escape. Good clearance. 

7. No fire behavior prediction required 

8. Can be written to be good up to 3 years per site, with annual review. 

9. Burn day required. 

10. Less than (<) one acre in size. 

11. Complexity level should rate as level 3 

12. Intended for admin sites, campgrounds, occupancy trespass, etc. 
46

Environmental Assessment Met (where documented): 

Estimated Cost: 1202: Funding Code: 

Project Area Description (Attach Map of Burn Area) 

Burn Objectives: 

Number, Species, and Size of Piles: 

Adjacent Fuel Description: 
47

Weather Forecasts 

The Pile Burn Boss is responsible for weather being taken every hour while burning to ensure prescription 

compliance. Contact the Emergency Communications Center (ECC) for weather forecasts and burn day 

designation. Contact ECC by radio when ignition is starting, giving legal description of area burning; and 

when burning is over, giving number of acres or piles burned. 

Prescription: 

Season of Burn (Fall, Spring, Summer, Winter): 

Acceptable Range Desired 

Air Temperature 

Relative Humidity 

Wind Speed 

Fuel Moisture 1 Hour T.L. 

10 Hour T.L. 

100 Hour T.L. 

Adjacent Live Fuel Moisture 

Wind Direction Preferred Acceptable: Unacceptable: 
48

Smoke Management 

Permitting Agency: 

Total Tons Per Acre Emissions: 

Distance and Direction from Smoke Sensitive Area(s): 

Necessary Transport Wind Direction(s): 

Visibility Hazard(s) (i.e., roads, airports, etc.): 

Actions to Reduce Visibility Hazard(s): 

Can Residual Smoke Be a Problem? 

Other Considerations: 

Special Constraint(s)/Consideration(s): 
49

Firing Technique: 

Holding Force Instructions: 

Mop Up Instructions 
50

Contact Plan 

Who will notify the following and when? 

Key People: 

Local Landowners: 

Private Land Within Proposed Burn (Identify on Map): 

Fire Protection Agencies: 

Dispatcher: 

Public Affairs Officer: 

News Releases to Local Papers and News Media: 
51

Safety Plan 

All line employees involved in the actual burning of standing and/or piled fuels will have on their person 

and use as necessary the following protective clothing: 

Hard hat 

Goggles 

Gloves 

Fire resistant pants 

Fire resistant shirt 

Fire shelter 

Laced boots as used in fire suppression 

Employees involved in a project with an assignment not related to actual burning should have with them 

all of the above safety equipment and be so equipped if their unplanned duties expose them to line work 

and/or the actual burning. 

Each burning plan will designate fire safety responsibility. This designation should include the following 

considerations: 

Escape routes 

Safety areas 

Closest recognized burn treatment facility and specific methods of travel to burn center or hospital 

Hospitals 

Travel Time Helipad Burn 

Center Name Address Air/Ground Phone Yes/No Yes/No 

 

 

 

 

 

 

 

 

Medical Emergency Procedures 

Give First Aid at scene. 

Contact Maui County Fire Department 

Make transportation arrangements. 

Comments: 
52

Debris & Pile Burning Checklist 

A “NO” response to any item means STOP! 

YES NO

1. Are all fire prescriptions met?

2. Has dispatch been notified?

3. Is it a permissive burn day?

4. Is fire weather forecast favorable?

5. Are all personnel required in the burn plan on site?

6. Have all personnel been briefed on the burn plan requirements?

7. Have all personnel been briefed on safety hazards, escape routes and safety orders?

8. Is all the required equipment in place an in working order?

9. Are all personnel aware of mop up requirements before abandonment?

10. Are all answers to all the above questions “Yes”?

If all ten questions have been answered “Yes”, you may proceed with lighting. 
53

APPENDIX I: DELEGATION OF AUTHORITY

DELEGATION OF AUTHORITY 

Region 1, U.S. Fish and Wildlife Service 

Maui National Wildlife Refuge Complex 

 , you are assigned as Incident Commander of the 

 Incident on the National Wildlife Refuge. You have full 

authority and responsibility for managing the fire suppression operation on this incident within the 

framework of legal statute, current policy, broad direction, and the Wildland Fire Situation Analysis 

(WFSA). Your primary responsibility is to achieve complete control of the fire by organizing and 

directing the fire suppression organization in an effective, efficient, economical and most importantly, safe 

manner. 

You should be guided in your duties by the fire job descriptions relating to Incident Commander, as found 

in the Fireline Handbook. Strongly consider long-term ecosystem health, and the effects of suppression 

actions in the development of appropriate suppression responses. These issues are to be addressed and 

documented in the WFSA. 

You are accountable to the Refuge Manager, of the 

Maui National Wildlife Refuge Complex, who is the Line Officer. may 

serve as the Line Officer Designee for this incident. 

You will immediately notify me in person in the event of: 

(1) a serious injury or fatality, 

(2) threat to private property, 

(3) if the incident exceeds the limits of the selected alternative of the WFSA. 

Much of the Refuge Complex is home to endangered species. Your job as Incident Commander is critical, 

as you must minimize damage to the habitats, as well as provide for firefighter safety. Minimum 

environmental suppression tactics shall be used, commensurate with forecasted and threatened resource 

values. 

You are to be guided by the Wildland Fire Situation Analysis, approved by , 

Project Leader. 

The Resource Advisor assigned to your incident will be . 

 

Glynnis Nakai, Refuge Manager Date 

Maui National Wildlife Refuge Complex 
54

APPENDIX J: WILDLAND FIRE SITUATION ANALYSIS

WILDLAND FIRE 

SITUATION ANALYSIS 

Incident Name: 

Jurisdiction: 

Date and Time Completed: 
55

I. WILDLAND FIRE SITUATION ANALYSIS

A. Jurisdiction(s) B. Geographic Area

C. Unit(s) D. WSFA #

E. Fire Name F. Incident #

G. Accounting Code: 

H. Date/Time Prepared: @

I. Attachments: 

Complexity Matrix/Analysis *

Risk Assessment/Analysis *

Probability of Success *

Consequences of Failure *

Maps *

Decision Tree **

Fire Behavior Projections *

Calculations of Resource Requirements *

Other (specify)

* Required

** Required by FWS

This page is completed by the Agency Administrator(s)
56

II. OBJECTIVES AND CONSTRAINTS

A. Objectives (must be specific and measurable)

1. Safety

- Public

- Firefighter

2. Economic

3. Environmental

4. Social

5. Other

B. Constraints

This page is completed by the Agency Administrator(s)
57

III. ALTERNATIVES

A B C

A. Wildland Fire Strategy

B. Narrative

C. Resources Needed

Handcrews

Engines

Dozers

Airtankers

Helicopters

D. Final Size

E. Estimated Contain/ 

Control Date

F. Costs

G. Risk Assessment

Probability of 

Success

Consequences of 

Failure

H. Complexity

I. Attach maps for each alternative

This page is completed by the Agency Administrator(s) and FMO/Incident Commander
58

IV. EVALUATION OF ALTERNATIVES

A. Evaluation Process A B C

Safety

Firefighter

Aviation

Public

Sum of Safety Values

Economic

Forage

Improvements

Recreation

Timber

Water

Wilderness

Wildlife

Other (specify)

Sum of Economic Values

Environmental

Air

Visual

Fuels

T & E Species

Other (specify)

Sum of Environmental Values

Social

Employment

Public Concern

Cultural

Other (specify)

Sum of Social Values

Other

This page is completed by the Agency Administrator(s) and FMO/Incident Commander
59

V. ANALYSIS SUMMARY

Alternatives A B C

A. Compliance with Objectives

Safety

Economic

Environmental

Social

Other (specify)

B. Pertinent Data

Final Fire Size

Complexity

Suppression Cost

Resource Values

Probability of Success

Consequences of Failure

C. External/Internal Influences

National & Geographic Preparedness Level: 

Incident Priority: 

Resource Availability: 

Weather Forecast (long range): 

Fire Behavior Projections: 

This page is completed by the Agency Administrator(s) and FMO/Incident Commander
60

VI. DECISION

The Selected Alternative is: 

Rationale: 

 

Agency Administrator’s Signature

 

Date/Time

This page is completed by the Agency Administrator(s) or designate
61

VII. DAILY REVIEW

To be reviewed daily to determine if still valid until containment or control

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IF WFSA IS NO LONGER VALID, A NEW WFSA WILL BE COMPLETED!

This page is completed by the Agency Administrator(s) or designate
62

VIII. FINAL REVIEW

The elements of the selected alternative were met on:

Date Time

By: 

Agency Administrator(s)
63

INSTRUCTIONS

Section I. WFSA Information Page

A. Jurisdiction(s): Assign the agency or agencies that have or could have fire protection responsibility, e.g., 

USFWS, BLM, etc. 

B. Geographic Area: Assign the recognized "Geographic Coordination Area" the fire is located in, e.g., 

Northwest, Northern Rockies, etc. 

C. Unit(s): Designate the local administrative unit(s), e.g., Hart Mountain Refuge Area, Flathead Indian 

Reservation, etc. 

D. WFSA #: Identify the number assigned to the most recent WFSA for this fire. 

E. Fire Name: Self-explanatory. 

F. Incident #: Identify the incident number assigned to the fire. 

G. Accounting Code: Insert the local unit's accounting code. 

H. Date/Time Prepared: Self-explanatory. 

I. Attachments: Check here to designate items used to complete the WFSA. "Other could include data or 

models used in the development of the WFSA. Briefly describe the "other" items used. 

Section II. Objectives and Constraints

A. Objectives: Specify objectives that must be considered in the development of alternatives. Safety 

objectives for firefighter, aviation, and public must receive the highest priority. Suppression objectives 

must relate to resource management objectives in the unit resource management plan. 

Economic objectives could include closure of all or portions of an area, thus impacting the public, or 

impacts to transportation, communication, and resource values. 

Environmental objectives could include management objectives for airshed, water quality, wildlife, etc. 

Social objectives could include any local attitudes toward fire or smoke that might affect decisions on the 

fire. 

Other objectives might include legal or administrative constraints which would have to be considered in 

the analysis of the fire situation, such as the need to keep the fire off other agency lands, etc. 

B. Constraints: List constraints on wildland fire action. These could include constraints to designated 

wilderness, wilderness study areas, environmentally or culturally sensitive areas, irreparable damage to 

resources or smoke management/air quality concerns. Economic constraints, such as public and 

agency cost, could be considered here.
64

Section III. Alternatives

A. Wildland Fire Management Strategy: Briefly describe the general wildland fire strategies for each 

alternative. Alternatives must meet resource management plan objectives. 

B. Narrative: Briefly describe each alternative with geographic names, locations, etc., that would be used 

when implementing a wildland fire strategy. For example: "Contain within the Starvation Meadows' 

watershed by the first burning period." 

C. Resources Needed: Resources described must be reasonable to accomplish the tasks described in 

Section III.B. It is critical to also look at the reality of the availability of these needed resources. 

D. Final Fire Size: Estimated final fire size for each alternative at time of containment. 

E. Estimated Contain/Control Date: Estimates of each alternative shall be made based on predicted 

weather, fire behavior, resource availability, and the effects of suppression efforts. 

F. Cost: Estimate all incident costs for each alternative. Consider mop-up, rehabilitation, and other costs 

as necessary. 

G. Risk Assessment - Probability of Success/Consequences of Failure: Describe probability as a 

percentage and list associated consequences for success and failure. Develop this information from 

models, practical experience, or other acceptable means. Consequences described will include fire size, 

days to contain, days to control, costs, and other information such as park closures and effect on critical 

habitat. Include fire behavior and long-term fire weather forecasts to derive this information. 

H. Complexity: Assign the complexity rating calculated in "Fire Complexity Analysis" for each alternative, 

e.g., Type II, Type I. 

I. A map for each alternative should be prepared. The map will be based on the "Probability of 

Success/Consequences of Failure" and include other relative information.

Section IV. Evaluation of Alternatives

A. Evaluation Process: Conduct an analysis for each element of each objective and each alternative. 

Objectives shall match those identified in Section II.A. Use the best estimates available and quantify 

whenever possible. Provide ratings for each alternative and corresponding objective element. Fire 

effects may be negative, cause no change, or may be positive. Examples are: 1) a system which 

employs a "-" for negative effect, a "0" for no change, and a "+" for positive effect; 2) a system which 

uses a numeric factor for importance of the consideration (soils, watershed, political, etc.) and assigns 

values (such as -1 to +1, - 100 to +100, etc.) to each consideration, then arrives at a weighted average. 

If you have the ability to estimate dollar amounts for natural resource and cultural values, this data is 

preferred. Use those methods which are most useful to managers and most appropriate for the situation 

and agency. To be able to evaluate positive fire effects, the area must be included in the resource 

management plan and consistent with prescriptions and objectives of the Fire Management Plan. 

Sum of Economic Values: Calculate for each element the net effect of the rating system used for each 

alternative. This could include the balance of pluses (+) and minuses (-), numerical rating (-3 and +3), or 

natural and cultural resource values in dollar amounts. (Again, resource benefits may be used as part of 

the analysis process when the wildland fire is within a prescription consistent with approved Fire 

Management Plans and in support of the unit's Resource Management Plan.) 
65

Section V. Analysis Summary

A. Compliance with Objectives: Prepare narratives that summarize each alternative's effectiveness in 

meeting each objective. Alternatives that do not comply with objectives are not acceptable. Narrative 

could be based on effectiveness and efficiency. For example: "most effective and least efficient," "least 

effective and most efficient," or "effective and efficient." Or answers could be based on a two-tiered 

rating system such as "complies with objective" and "fully complies with or exceeds objective." Use a 

system that best fits the manager's needs. 

B. Pertinent Data: Data for this Section has already been presented, and is duplicated here to help the 

Agency Administrator(s) confirm their selection of an alternative. Final Fire Size is displayed in Section 

III.D. Complexity is calculated in the attachments and displayed in Section III.H. Costs are displayed on 

page 4. Probability of Success/Consequences of Failure is calculated in the attachments and displayed 

in Section III.G. 

C. External and Internal Influences: Assign information and data occurring at the time the WFSA is signed. 

Identify the Preparedness Index (1 through 5) for the National and Geographic levels. If available, 

indicate the Incident Priority assigned by the MAC Group. Designate the Resource Availability status. 

This information is available at the Geographic Coordination Center, and is needed to select a viable 

alternative. Designate "yes," indicating an up-to-date weather forecast has been provided to, and used 

by, the Agency Administrator(s) to evaluate each alternative. Assign information to the "Other" category 

as needed by the Agency Administrator(s). 

Section IV. Decision

Identify the alternative selected. Must have clear and concise rationale for the decision, and a signature with 

date and time. Agency Administrator(s) is mandatory.

Section VII. Daily Review 

The date, time, and signature of reviewing officials are reported in each column for each day of the incident. 

The status of Preparedness Level, Incident Priority, Resource Availability, Weather Forecast, and WFSA 

validity is completed for each day reviewed. Ratings for the Preparedness Level, Incident Priority, Resource 

Availability, Fire Behavior, and Weather Forecast are addressed in Section V.C. Assign a “yes” under 

"WFSA Valid" to continue use of this WFSA. A "no" indicates this WFSA is no longer valid and another 

WFSA must be prepared or the original revised. 

Section VIII. Final Review 

This Section is completed by the Agency Administrator(s). A signature, date, and time are provided once all 

conditions of the WFSA are met. 
66

A GUIDE FOR ASSESSING FIRE COMPLEXITY

The following questions are presented as a guide to assist the Agency Administrator(s) and staff in analyzing 

the complexity or predicted complexity of a wildland fire situation. Because of the time required to assemble 

or move an Incident Management Team to wildland fire, this checklist should be completed when a wildland 

fire escapes initial attack and be kept as a part of the fire records. This document is prepared concurrently 

with the preparation of (and attached to) a new or revised Wildland Fire Situation Analysis. It must be 

emphasized this analysis should, where possible, be based on predictions to allow adequate time for 

assembling and transporting the ordered resources. 

Use of the Guide:

1. Analyze each element and check the response "yes" or "no." 

2. If positive responses exceed, or are equal to, negative responses within any primary factor (A 

through G), the primary factor should be considered as a positive response. 

3. If any three of the primary factors (A through G) are positive responses, this indicates the fire 

situation is, or is predicted to be, Type I. 

4. Factor H should be considered after all the above steps. If more than two of these items are 

answered "yes," and three or more of the other primary factors are positive responses, a Type I team 

should be considered. If the composites of H are negative, and there are fewer than three positive 

responses in the primary factors (A-G), a Type II team should be considered. If the answers to all 

questions in H are negative, it may be advisable to allow the existing overhead to continue action on 

the fire.

GLOSSARY OF TERMS 

Potential for blow-up conditions - Any combination of fuels, weather, and topography excessively 

endangering personnel.

Rate or endangered species - Threat to habitat of such species or, in the case of flora, threat to the 

species itself. 

Smoke management - Any situation which creates a significant public response, such as smoke in a 

metropolitan area or visual pollution in high-use scenic areas. 

Extended exposure to unusually hazardous line conditions - Extended burnout or backfire situations, 

rock slide, cliffs, extremely steep terrain, abnormal fuel situation such as frost killed foliage, etc. 

Disputed fire management responsibility - Any wildland fire where responsibility for management is not 

agreed upon due to lack of agreements or different interpretations, etc. 

Disputed fire policy - Differing fire policies between suppression agencies when the fire involves multiple 

ownership is an example. 

Pre-existing controversies - These may or may not be fire management related. Any controversy drawing 

public attention to an area may present unusual problems to the fire overhead and local management. 

Have overhead overextended themselves mentally or physically - This is a critical item that requires 

judgment by the responsible agency. It is difficult to write guidelines for this judgment because of the wide 

differences between individuals. If, however, the Agency Administrator feels the existing overhead cannot 

continue to function efficiently and take safe and aggressive action due to mental or physical reasons, 

assistance is mandatory.
67

FIRE COMPLEXITY ANALYSIS 

A. FIRE BEHAVIOR: Observed or Predicted YES/NO 

 1. Burning Index (from on-site measurement of weather conditions) predicted 

 to be above the 90% level using the major fuel model in which the fire is 

 burning. 

 2. Potential exists for “blowup” conditions (fuel moisture, winds, etc.). 

 3. Crowning, profuse or long-range spotting. 

 4. Weather forecast indicating no significant relief or worsening conditions. 

Total 

B. RESOURCES COMMITTED 

 1. 200 or more personnel assigned. 

 2. Three or more divisions. 

 3. Wide variety of special support personnel. 

 4. Substantial air operation which is not properly staffed. 

 5. Majority of initial attack resources committed. 

Total 

C. RESOURCES THREATENED 

 1. Urban interface. 

 2. Developments and facilities. 

 3. Restricted, threatened, or endangered species habitat. 

 4. Cultural Sites. 

 5. Unique natural resources, special designation zones, or wilderness. 

 6. Other special resources. 

Total 
68

D. SAFETY YES/NO 

 1. Unusually hazardous fire line conditions. 

 2. Serious accidents or fatalities. 

 3. Threat to safety of visitors from fire and related operations. 

 4. Restricted and/or closures in effect or being considered. 

 5. No night operations in place for safety reasons. 

Total 

E. OWNERSHIP 

 1. Fire burning or threatening more than one jurisdiction. 

 2. Potential for claims (damages). 

 3. Conflicting management objectives. 

 4. Disputes over fire management responsibility. 

 5. Potential for unified command. 

Total 

F. EXTERNAL INFLUENCES 

 1. Controversial wildland fire management policy. 

 2. Pre-existing controversies/relationships. 

 3. Sensitive media relationships. 

 4. Smoke management problems. 

 5. Sensitive political interests. 

 6. Other external influences. 

Total 
69

G. CHANGE YES/NO 

 1. Change in strategy to confine/contain to control. 

 2. Large amount of unburned fuel within planned perimeter. 

 3. WFSA invalid or requires updating. 

Total 

H. EXISTING OVERHEAD 

 Worked two operational periods without achieving initial objectives. 

 Existing management organization ineffective. 

 IMT overextended themselves mentally and/or physically. 

 Incident action plans, briefings, etc. missing or poorly prepared. 

Total 

I. SIGNATURE 

 

Name and Title Date and Time 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix H Statement of Compliance H-1 

Appendix H: 

STATEMENT OF COMPLIANCE

for Implementation of the 

Keālia Pond National Wildlife Refuge, Maui County, Hawai‘i

Comprehensive Conservation Plan 

The following Executive orders and legislative acts have been reviewed as they apply to 

implementation of the Keālia Pond NWR CCP. 

National Environmental Policy Act (1969). The planning process has been conducted in 

accordance with NEPA Implementing Procedures, Department of the Interior and Service 

procedures, and has been performed in coordination with the affected public. 

The CCP is programmatic in many respects and specific details of certain projects and actions cannot 

be determined until a later date depending on funding and implementation schedules. Certain projects 

or actions may require additional NEPA compliance. 

National Historic Preservation Act (1966). The implementation of the CCP should not affect 

cultural resources. The proposed action does not meet the criteria of an effect or adverse effect as an 

undertaking defined in 36 CFR 800.9 and 614 FW 2. The Service will comply with the National 

Historic Preservation Act if any management actions have the potential to affect any historic 

properties which may be present. 

Executive Order 12372. Intergovernmental Review. Coordination and consultation with affected 

Tribal, local, and State governments, other Federal agencies, and the landowners has been completed 

through personal contact by Service planners, refuge managers, and supervisors. 

Executive Order 12898. Federal Actions to Address Environmental Justice in Minority and 

Low-Income Populations. All Federal actions must address and identify, as appropriate, 

disproportionally high and adverse human health or environmental effects of its programs, policies, 

and activities on minority populations, low-income populations, and Indian Tribes in the United 

States. The CCP was evaluated and no adverse human health or environmental effects were identified 

for minority or low-income populations, Indian Tribes, or anyone else. 

Wilderness Preservation Act of 1964. The Service has evaluated the suitability of the Refuge for 

wilderness designation and determined it does not qualify.

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

System Improvement Act of 1997 (16 U.S.C. 668dd-668ee). Appropriate Use findings and 

Compatibility Determinations have been prepared for the following uses: Wildlife Observation, 

Interpretation and Photography; Environmental Education; and Research. 

Executive Order 13186. Responsibilities of Federal Agencies to Protect Migratory Birds. The 

CCP is consistent with Executive Order 13186 because the CCP and NEPA analyses evaluate the 

effects of agency actions on migratory birds. 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

H-2 Appendix H: Statement of Compliance 

Endangered Species Act of 1973. The Service will conduct consultations under Section 7 of the 

ESA for any refuge management program actions that have the potential to affect listed species. 

Coastal Zone Management Act, Section 307. Section 307(c)(1) of the Coastal Zone Management 

Act of 1972, as amended, requires each Federal agency conducting or supporting activities directly 

affecting the coastal zone, to conduct or support those activities in a manner which is, to the 

maximum extent practicable, consistent with approved state coastal management programs. The CCP 

is consistent with Coastal Zone Management Act because CCP implementation would protect the 

coastal zone from adverse impacts as a result of modification or destruction. 

Executive Order 11990. Protection of Wetlands. The CCP is consistent with Executive Order 

11990 because CCP implementation would protect and enhance existing wetlands. 

Executive Order 11988. Floodplain Management. Under this order Federal agencies "shall take 

action to reduce the risk of flood loss, to minimize the impact of floods on human safety, health and 

welfare, and to restore and preserve the natural and beneficial values served by flood plains." The 

CCP is consistent with Executive Order 11988 because CCP implementation would protect 

floodplains from adverse impacts as a result of modification or destruction. 

Integrated Pest Management (IPM), 517 DM 1 and 569 FW 1 

In accordance with 517 DM 1, an integrated pest management (IPM) approach has been adopted to 

eradicate, control, or contain pest and invasive species on the refuge. In accordance with 517 DM 1, 

only pesticides registered with the USEPA in full compliance with FIFRA and as provided in 

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

jurisdiction. 

 _______________________________ _________________________ 

 Chief, Division of Refuge Planning Date 
Keālia Pond National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

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Appendix J. Acronyms and Abbreviations J-1 

Appendix J. Common Acronyms and Abbreviations 

A&B Alexander and Baldwin 

ac acre(s) 

Administration Act National Wildlife Refuge System Administration Act of 1966 

BCE Before Common Era 

BIDEH Biological Integrity, Diversity, and Environmental Health 

BMPs Best Management Practices 

Bti Bacillus thuringiensis var israelensis

CCP Comprehensive Conservation Plan 

CD Compatibility Determination 

CE Common Era 

CFLHD Central Federal Lands Highway Division 

CFR Code of Federal Regulations 

cfs cubic feet per second 

CO2 carbon dioxide 

Complex Maui National Wildlife Refuge Complex 

DBEDT Hawai‘i Department of Business, Economic Development, and Tourism 

DIN dissolved inorganic N concentration 

DLNR Hawai‘i Department of Land and Natural Resources 

DM Department Manual 

DO dissolved oxygen 

DOA Hawai‘i Department of Agriculture 

DOCARE Hawai‘i Division of Conservation and Resource Enforcement 

DOE Hawai‘i Department of Education 

DOFAW Hawai‘i Division of Forestry and Wildlife 

DOH Hawai‘i Department of Health 

DOI U. S. Department of Interior 

EA Environmental Assessment 

EE environmental education 

e.g. exempli gratia, “for example” 

ENSO El Niño Southern Oscillation 

EPA Environmental Protection Agency 

ESA Endangered Species Act 

F Fahrenheit 

FONSI Finding of No Significant Impact 

ft Feet (Foot) 

GAO Government Accountability Office 

GHG greenhouse gas(es) 

gpm gallon (U.S. fluid) per minute

HDOT Hawai‘i Department of Transportation 

HQ/VC headquarters and visitor center 

Improvement Act National Wildlife Refuge System Improvement Act of 1997 

I&M inventory and monitoring 

in inch(es) 

IPCC Intergovernmental Panel on Climate Change 

IPM Integrated Pest Management 
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J-2 Appendix J. Acronyms and Abbreviations 

lb(s) pound(s) 

LCA Land Commission Awards 

MCPD Maui County Planning Department 

mgd Million gallons per day 

mi mile(s) 

MLLW mean lower low water 

mm millimeter(s) 

MOA Memorandum of Agreement 

N Nitrogen 

NAGPRA Native American Graves Repatriation Act 

NAS Naval Air Station 

NEPA National Environmental Policy Act 

NOAA National Oceanic and Atmospheric Administration 

NOI Notice of Intent 

NTU Nephelometric Turbidity Unit 

NRCS Natural Resources Conservation Service 

NWHI Northwestern Hawaiian Islands 

NWR National Wildlife Refuge 

OPIC Overseas Private Investment Corporation 

P Phosphorus 

PCJV Pacific Coast Joint Venture 

PDO Pacific Decadal Oscillation 

pH potential (of) hydrogen 

PICCC Pacific Islands Climate Change Cooperative 

ppb parts per billion 

ppm parts per million 

ppt parts per trillion 

PVC polymerizing vinyl chloride 

Refuge System National Wildlife Refuge System 

RHPO Regional Historic Preservation Officer 

Service, USFWS U.S. Fish and Wildlife Service 

SHPO State Historic Preservation Officer 

Si silicon 

SLAMM Sea Levels Affecting Marshes Model 

SLR Sea Level Rise 

SRP soluble reactive P 

SRS soluble reactive Si 

SUP Special Use Permit 

T&E Threatened and Endangered 

TP total phosphorus 

TN total nitrogen 

TSS total suspended solids 

USACE U.S. Army Corps of Engineers 

USCG U.S. Coast Guard 

USDA U.S. Department of Agriculture 

USGS U.S. Geological Survey 

WWII World War II 

YCC Youth Conservation Corps 

yd(s) yard(s) 
U.S. Department of the Interior

U.S. Fish & Wildlife Service

Maui National Wildlife Refuge Complex

Milepost 6 Mokulele Highway

Kı ̄hei, Hawai‘i 96753

Phone: 808/875 1582

Fax: 808/875 2954

http://www.fws.gov

National Wildlife Refuge System Information

1 800/344 WILD

August 2011

The mission of the U.S. Fish & Wildlife Service

is working with others to conserve, protect, and

enhance fish, wildlife, and plants and their habitats

for the continuing benefit of the American people.

Front Cover Inset Photos Back Cover

Ae‘o Koloa ma ̄pu ‘Auku‘u

USFWS ©Tom Dove ©Kanalu Chock

Ko ̄lea

©Mike Walther