Rose Atoll 

National Wildlife Refuge 

Comprehensive Conservation Plan

Prepared by:

Rose Atoll National Wildlife Refuge

c/o National Park Service

Pago Pago, American Samoa 96799 

Pacific Reefs and Hawaiian and Pacific Islands Planning Team

U.S. Fish and Wildlife Service

300 Ala Moana Boulevard, Room 5-231 

Honolulu, Hawai‘i 96850 

May 2014 
U.S. Fish and Wildlife Service 

Rose Atoll National Wildlife Refuge 

Comprehensive Conservation Plan 

Approval Submission 

In accordance with the National Wildlife Refuge System Administration Act of 1966, as 

amended, a Comprehensive Conservation Plan (CCP) has been preparedfor Rose Atoll 

National Wildlife Refuge. The purpose of the CCP is to specify a management direction for 

the Refuge for the next 15 years. The CCP charts a vision of the Refuge's future desired 

conditions, the types of habitat that will be provided, species protected, public use, partnership 

opportunities, and the management actions needed to achieve that vision. The effects of the 

CCP on the human environment were described in the Draft CCP and Environmental 

Assessment. This CCP is submitted for approval by the Regional Director. 

Submitted by: 

~QJAAJJi;/A Frank Pendleton 

Refuge Manager, Rose Atoll National Wildlife Refuge 

Approved::::-;--'~'-;;;;--· ~ Robyn Thorson, ...::..._:,~:----'--;-;:::-----:-----::::-----:---:-:;:---c:---:--;::---q-'-±-Z:=-7;,"--f-...L...- Regional Director, Region I, Portland, Oregon ate 

t-(;"\~ 
FINDING OF NO SIGNIFICANT IMPACT

for the

Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

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

Plan (CCP) and Environmental Assessment (EA) for Rose Atoll National Wildlife Refuge 

(Refuge). The CCP will guide management of the Refuge for the next 15 years. The CCP and 

EA described the Service’s proposals for managing the Refuge and their effects on the human 

environment under two alternatives, including the no action alternative. 

Decision

Following comprehensive review and analysis of the two alternatives, the Service selected 

Alternative B for implementation because it is the alternative that best meets the following 

criteria:

• Achieves the mission of the National Wildlife Refuge System;

• Achieves the purposes of the Refuge;

• Will be able to achieve the vision and goals for the Refuge; 

• Maintains and restores the ecological integrity of Refuge habitats and populations;

• Addresses the important issues identified during the scoping process; 

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

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

species recovery.

Summary of the Actions to be Implemented

Implementing the selected alternative will have no significant impacts on any of the 

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

alternative will protect, maintain, and enhance habitat for priority species and resources of 

concern. A detailed summary of the CCP actions we will implement can be found in Chapter 

2, Table 2.1; however major management actions include: 

• Protecting, restoring, and maintaining habitats including the lagoon, perimeter 

crustose coralline algal reef, ava, beach strand, and littoral forest. This will include 

developing monitoring protocols, installing a remote camera system, increasing 

surveys, implementing a rapid response program to nonnative species, restoring 

native plants, and increasing applied research;

• Protecting, restoring, and maintaining the species that rely on the habitats above, 

including corals, fish, seabirds, shorebirds, sea turtles, native plants, faisua, and 

invertebrates; 

• Expanding outreach, interpretation, and environmental education by working with 

partners to develop materials and curriculum; 

• Protecting and perpetuating cultural resources related to Rose Atoll; and 

• Focusing scientific information and research needs to better support adaptive 

management on the Refuge. 
Public Involvement and Changes to the Selected Alternative Based on Comments 

Beginning with the public scoping in 2009, the planning process incorporated public 

involvement in developing and reviewing the CCP. This included seven public open 

houses/meetings, three planning updates, updates provided through meetings with partners, 

elected officials, and chiefs, Notices of Availability in the Federal Register, website postings, 

mail and email list circulations, news releases, and public review and comment on the Draft 

CCP/EA during the extended public comment period of October 9-November 27, 2012. Public 

involvement details, our responses to comments, and any changes made to the CCP are 

outlined in detail in Appendix J. 

Based on public comments received, two new research strategies (i.e., to investigate breeding 

seabird diets and to correlate seabird reproduction with oceanographic conditions and prey 

locations) were added in Objective 6.2, clarification on the relationship between seabirds and 

pelagic fish was made on a section of the biological chapter, and a strategy to work with the 

National Oceanic and Atmospheric Administration to identifY the Refuge on nautical charts 

and other marine information products was added to a revised law enforcement section in 

Chapter 2. Some additional text changes were made to improve readability and accuracy. 

Conclusions 

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

have determined that implementing Alternative B as the CCP for management of Rose Atoll 

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

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

Environmental Policy Act of I 969. Accordingly, the Service is not required to prepare an 

environmental impact statement. 

S. Regional Director, Region I 

't-t.O..<$' Portland, Oregon 

Supporting References 

U.S. Fish and Wildlife Service. 2012. Rose Atoll National Wildlife Refuge Draft 

Comprehensive Conservation Plan and Environmental Assessment. U.S. Department of the 

Interior, Fish and Wildlife Service, Region I. Portland, OR. 313 pp. 

U.S. Fish and Wildlife Service. 2013. Rose Atoll National Wildlife Refuge Comprehensive 

Conservation Plan. U.S. Department of the Interior, Fish and Wildlife Service, Region I. 

Portland, OR. 

Note: This Finding ofNo Significant Impact and supporting references are on file at the Rose 

Atoll NWR in the National Park Service office, Pago Pago, American Samoa; the Pacific Reefs 

National Wildlife Refuge Complex, 300 Ala Moana Boulevard, Room 5-23 I, Honolulu, 

Hawai'i, 96826; and U.S. Fish and Wildlife Service, Division of Planning and Visitor Services, 

9 I I NE 1 I th Avenue, Portland, Oregon, 97232. These documents can also be found at 

www.fws.gov/roseatolllplanning.htrnl. These documents are available for public inspection. 

Interested and affected parties are being notified of our decision. 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Table of Contents i

Table of Contents

Chapter 1. Introduction and Background ......................................................................................1-1

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

1.2 Legal and Policy Guidance .......................................................................................................1-2

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

1.2.2 National Wildlife Refuge System ..................................................................................... 1-5

1.2.3 National Wildlife Refuge System Mission and Goals....................................................... 1-5

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

1.2.5 Presidential Proclamation 8337 ........................................................................................ 1-6

1.2.6 Other Laws and Mandates................................................................................................. 1-7

1.3 Refuge Establishment and Purposes.........................................................................................1-8

1.3.1 Refuge Establishment ....................................................................................................... 1-8

1.3.2 Purpose.............................................................................................................................. 1-8

1.3.3 Land Status and Ownership .............................................................................................. 1-8

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

1.5 Relationship to Other Planning Efforts...................................................................................1-12

1.6 Planning and Issue Identification............................................................................................1-13

1.6.1 Issues Addressed in the CCP .......................................................................................... 1-13

1.6.2 Issues outside the Scope of the CCP............................................................................... 1-13

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

2.1 Overview...................................................................................................................................2-1

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

2.3 Rose Atoll NWR Management ................................................................................................2-9

2.3.1 Goal 1: Protect and maintain the lagoon habitats to meet the life-history needs of 

native species in this community. .............................................................................................. 2-9

2.3.2 Goal 2: Restore, protect, and maintain the perimeter crustose coralline algal reef to 

meet the life-history needs of native species in this community. ............................................ 2-11

2.3.3 Goal 3: Protect and maintain the natural state of the ava (channel) to protect all other 

Refuge habitats and the hydrology of the lagoon. ................................................................... 2-13

2.3.4 Goal 4: Restore, protect, and maintain the beach strand habitat to meet the lifehistory needs of native species in this community................................................................... 2-14

2.3.5 Goal 5: Restore, protect, and maintain littoral forest to meet the life-history needs of 

native species in this community including plants, seabirds, shorebirds, landbirds, 

waterbirds, reptiles, and land crabs.......................................................................................... 2-16

2.3.6 Goal 6: Gather scientific information (inventories, monitoring, assessments, and 

research) to support adaptive management decisions under objectives for Goals 1-5. ........... 2-18

2.3.7 Goal 7: Strengthen resource conservation and the public’s shared stewardship of the 

ecological, geologic, and cultural richness of the Refuge by providing outreach, 

interpretation, and environmental education opportunities...................................................... 2-22

2.3.8 Goal 8: Identify, protect, preserve, and interpret the Refuge’s Samoan cultural 

resources and facilitate, where appropriate, cultural practices. ............................................... 2-25

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

3.1 Climate......................................................................................................................................3-1

3.1.1 Climate Change................................................................................................................. 3-1

3.1.2 Climate Change at Rose Atoll........................................................................................... 3-2
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

ii Table of Contents

3.2 Hydrology .................................................................................................................................3-6

3.3 Topography and Bathymetry ....................................................................................................3-6

3.4 Geology and Geomorphology...................................................................................................3-7

3.5 Soils...........................................................................................................................................3-9

3.6 Environmental Contaminants..................................................................................................3-10

3.6.1 Military Use in WWII..................................................................................................... 3-10

3.6.2 Wreck of the Jin Shiang Fa 1993 ................................................................................... 3-10

3.7 Air Quality ..............................................................................................................................3-11

3.8 Water Quality..........................................................................................................................3-11

3.9 Surrounding Land and Water Use...........................................................................................3-12

Chapter 4. Biological Environment.................................................................................................4-1

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

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

4.2.1 Analysis of Priority Resources of Concern....................................................................... 4-3

4.3 Habitat Types............................................................................................................................4-7

4.3.1 Ava.................................................................................................................................. 4-11

4.3.2 Reef (Crest and Back)..................................................................................................... 4-12

4.3.3 Lagoon ............................................................................................................................ 4-12

4.3.4 Intertidal.......................................................................................................................... 4-13

4.3.5 Beach Strand ................................................................................................................... 4-14

4.3.6 Littoral Forest.................................................................................................................. 4-15

4.4 Threatened, Endangered, and Sensitive Species.....................................................................4-17

4.4.1 Tuli (Numenius tahitiensis) or Bristle-thighed Curlew................................................... 4-17

4.4.2 Tuli (Pluvialis fulva) or Pacific Golden Plover .............................................................. 4-18

4.4.3 I’a sa (Chelonia mydas) or Green Turtle ........................................................................ 4-18

4.4.4 Hawksbill Turtle (Eretmochelys imbricata) ................................................................... 4-19

4.4.5 Faisua (Tridacna maxima) or Giant Clam ...................................................................... 4-20

4.5 Seabirds...................................................................................................................................4-22

4.5.1 Tava’e’ula (Phaethon rubricauda) or Red-tailed Tropicbird ......................................... 4-22

4.5.2 Atafa (Fregata minor) or Great Frigatebird.................................................................... 4-23

4.5.3 Atafa (Fregata ariel) or Lesser Frigatebird .................................................................... 4-24

4.5.4 Fua’o (Sula dactylatra) or Masked Booby ..................................................................... 4-24

4.5.5 Fua’o (Sula leucogaster) or Brown Booby..................................................................... 4-25

4.5.6 Fua’o (Sula sula) or Red-footed Booby.......................................................................... 4-26

4.5.7 Gogo Uli (Anous minutus) or Black Noddy.................................................................... 4-27

4.5.8 Gogo (Anous stolidus) or Brown Noddy......................................................................... 4-28

4.5.9 Manu Sina (Gygis alba) or White Tern .......................................................................... 4-29

4.5.10 Gogo Uli (Onychoprion fuscatus) or Sooty Tern.......................................................... 4-30

4.5.11 Gogosina (Onychoprion lunatus) or Gray-backed Tern ............................................... 4-31

4.5.12 Gogosina (Sterna sumatrana) or Black-naped Tern..................................................... 4-32

4.6 Shorebirds and Wading Birds.................................................................................................4-33

4.6.1 Tuli (Arenaria interpres) or Ruddy Turnstone ............................................................... 4-34

4.6.2 Tuli (Calidris alba) or Sanderling .................................................................................. 4-34

4.6.3 Tuli (Tringa incana) or Wandering Tattler..................................................................... 4-34

4.6.4 Matu’u (Egretta sacra) or Pacific Reef Heron ............................................................... 4-34

4.7 Land Birds...............................................................................................................................4-35

4.7.1 Aleva (Eudynamis taitensis) or Long-tailed Cuckoo...................................................... 4-35

4.8 Invertebrates............................................................................................................................4-35
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Table of Contents iii

4.8.1 Tuitui (Sea Urchin) ......................................................................................................... 4-35

4.8.2 Terrestrial Invertebrates.................................................................................................. 4-36

4.9 Reef Building Species.............................................................................................................4-37

4.9.1 Coral................................................................................................................................ 4-37

4.9.2 Coralline Algae ............................................................................................................... 4-41

4.10 Fish........................................................................................................................................4-44

4.11 Invasive and Nuisance Species.............................................................................................4-47

4.11.1 Mammals....................................................................................................................... 4-47

4.11.2 Reptiles ......................................................................................................................... 4-49

4.11.3 Invertebrates.................................................................................................................. 4-49

4.11.4 Vegetation..................................................................................................................... 4-49

4.12 Wildlife and Habitat Research Inventory and Monitoring....................................................4-50

Chapter 5. Social and Economic Environment ..............................................................................5-1

5.1 Cultural Resources....................................................................................................................5-1

5.1.1 Historical Background ...................................................................................................... 5-1

5.1.2 Rose Atoll and Manu’a Islands......................................................................................... 5-2

5.2 Refuge Facilities.......................................................................................................................5-6

5.3 Public Use Overview ................................................................................................................5-6

5.4 Wildlife-Dependent Public Uses...............................................................................................5-6

5.4.1 Hunting ............................................................................................................................. 5-6

5.4.2 Fishing............................................................................................................................... 5-6

5.4.3 Wildlife Observation and Photography............................................................................. 5-6

5.4.4 Environmental Education.................................................................................................. 5-7

5.4.5 Interpretation/Outreach ..................................................................................................... 5-7

5.4.6 Cultural Resources Interpretation ..................................................................................... 5-7

5.5 Illegal Uses................................................................................................................................5-7

5.6 Social/Economic Environment .................................................................................................5-8

5.6.1 Communities near Rose Atoll National Wildlife Refuge ................................................. 5-8

5.6.2 Population, Housing, and Income..................................................................................... 5-8

5.6.3 Employment and Business................................................................................................ 5-9

5.6.4 Refuge Impact on Local Economies............................................................................... 5-10

5.6.5 Additional Economic Contributions............................................................................... 5-11

Appendices

Appendix A. Rose Atoll NWR Species Lists ....................................................................................A-1

Appendix B. Appropriate Use Findings.............................................................................................B-1

Appendix C. Compatibility Determinations......................................................................................C-1

Appendix D. Implementation.............................................................................................................D-1

Appendix E. Wilderness Review for Rose Atoll National Wildlife Refuge......................................E-1

Appendix F. Biological Resources of Concern.................................................................................. F-1

Appendix G. Integrated Pest Management (IPM) Program...............................................................G-1

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

Appendix I. Common Acronyms and Abbreviations.......................................................................... I-1

Appendix J. Summary of Public Involvement....................................................................................J-1

Appendix K. Cooperative Agreement and Presidential Proclamations.............................................K-1

Appendix L. Best Management Practices for Visitors to Rose Atoll.....................................L-1

Appendix M. CCP Team Members.......................................................................... .M-1
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

iv Table of Contents

Appendix N. References....................................................................................................................N-1

Figures

Figure 1-1. Regional and local area. ...................................................................................................1-3

Figure 1-2. Refuge overview and land status......................................................................................1-9

Figure 2-1. Management direction......................................................................................................2-7

Figure 3-1. Atoll formation.................................................................................................................3-8

Figure 4-1. Habitats. ...........................................................................................................................4-8

Tables

Table 2-1. Summary of Management Direction .................................................................................2-6

Table 4-1. Biological Integrity, Diversity, and Environmental Health...............................................4-2

Table 4-2. Priority Resources of Concern...........................................................................................4-5

Table 4-3. Shorebirds and Wading Birds of Primary Conservation Importance in the U.S. Pacific 

Region...............................................................................................................................................4-32

Table 5-1. Employment and Labor Income 2002 ...............................................................................5-9

Table 5-2. Economic Projections 2000-2015....................................................................................5-10
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Chapter 1. Introduction and Background 1-1 

Lovely Rose Atoll rises above the azure blue sea. Jean Kenyon/USFWS

Chapter 1. Introduction and Background 

Rose Atoll National Wildlife Refuge (NWR or Refuge) is located approximately 180 miles east of 

Tutuila in American Samoa. The next closest island to Rose is Ta’ū Island in Manu’a, 78 miles away. 

The 1,613-acre Refuge was established on August 24, 1973, with the American Samoa Government 

(ASG) by a cooperative agreement (Appendix K). It is the southernmost unit of the National Wildlife 

Refuge System (Refuge System) and shares the distinction with Jarvis Island NWR of being one of 

two NWRs located south of the equator. 

One of the smallest atolls in the world, Rose Atoll consists of a perimeter reef encircling a central 

lagoon. The atoll is a nearly square geographical feature, with sides that are approximately 1.5 miles 

in length. There are two low, sandy islands—Rose and Sand—located on the coralline algal reef. A 

single ava (channel) links the lagoon to the sea surrounding the atoll. The lagoon is roughly 1.2 miles 

wide and 98 feet deep. The Refuge provides habitat for migratory seabirds and shorebirds, sea turtles, 

and unique marine fish, coral reefs, and other invertebrates. 

Coral communities at Rose Atoll are distinct from reefs around the other islands in Samoa. The 

fringing reef is a striking pink hue due to the crustose coralline algae (CCA) that is the primary reefbuilding species at the atoll. The CCA reef plays a significant role at the atoll, stabilizing the 

perimeter and protecting the lagoon and islands from ocean swells. Unlike the rest of the Samoan 

Archipelago where they are harvested by humans, the spectacularly colored faisua (giant clams) are 

found in high densities at the Refuge. Similarly, fish density is very high and species diversity 

moderately high when compared to other reefs in the Samoan Archipelago. 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

1-2 Chapter 1. Introduction and Background

Rose Atoll’s beach strand provides important nesting sites for the threatened green turtle, which 

migrates between American Samoa and other Pacific Island nations. As the only terrestrial rat-free 

areas in American Samoa, Rose Atoll’s islands are vital nesting and roosting habitat supporting 12 

species of federally-protected seabirds and sea turtles. The Refuge’s tropical pu’a vai (Pisonia 

grandis) forest provides habitat for many nesting seabird species. This forest type is declining in the 

Pacific due to the effects of human habitation, coconut plantings, and pests such as rats and insects. 

1.1 Purpose and Need for the CCP

The purpose of developing the CCP is to provide the refuge manager with a 15-year management 

plan for the conservation of fish, wildlife, and plant resources and their related habitats, while 

providing opportunities for compatible, wildlife-dependent recreational uses if compatible. The CCP, 

when fully implemented, should achieve refuge purposes; help fulfill the Refuge System mission; 

maintain and, where appropriate, restore the biological integrity, diversity, and environmental health 

(BIDEH) of the refuge and the Refuge System; help achieve the goals of the National Wilderness 

Preservation System (NWPS); and meet other mandates. The CCP must be specific to the planning 

unit and identify the overarching wildlife, public use, or management needs for the refuge (602 FW 

3.4C1d). 

1.2 Legal and Policy Guidance

The U.S. Fish and Wildlife Service (Service), an agency within the Department of the Interior (DOI), 

is the principal Federal agency responsible for conserving, protecting, and enhancing fish, wildlife, 

and plants and their habitats. Refuge management is guided by Federal laws, Executive Orders, 

Service policies, and international treaties. Fundamental guidelines are found in the mission and 

goals of the Refuge System and the designated purposes of the Refuge as described in establishing 

legislation, Executive Orders, or other documents establishing, authorizing, or expanding a refuge.

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

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

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

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

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

administration of units of the Refuge System. 

1.2.1 U.S. Fish and Wildlife Service 

All refuges are managed by the Service, an agency within the Department of the Interior (DOI). The 

Service is the principal Federal agency responsible for conserving, protecting, and enhancing the 

Nation’s fish and wildlife populations and their habitats. 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. 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Chapter 1. Introduction and Background 1-3 

Figure 1-1. Regional and local area. 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

1-4 Chapter 1. Introduction and Background

The back sides of maps are blank to improve readability. 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Chapter 1. Introduction and Background 1-5 

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. 

1.2.2 National Wildlife Refuge System 

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

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

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

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

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

environmental education and interpretive activities on national wildlife refuges.

1.2.3 National Wildlife Refuge System Mission and Goals

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

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

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

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

policy (601 FW1), follow: 

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

endangered or threatened with becoming endangered; 

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

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

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

• Conserve those ecosystems, plant 

communities, wetlands of national or 

international significance, and landscapes 

and seascapes that are unique, rare, 

declining, or underrepresented in existing 

protection efforts; 

• Provide and enhance opportunities to 

participate in compatible wildlife-dependent 

recreation (hunting, fishing, wildlife 

observation and photography, and 

environmental education and interpretation); 

and 

• Foster understanding and instill appreciation 

of the diversity and interconnectedness of 

fish, wildlife, and plants and their habitats. 

1.2.4 National Wildlife Refuge System Administration Act of 1966

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

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

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

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

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

Faisua decorate the lagoon at Rose Atoll. 

Mark MacDonald/ASG-DMWR
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

1-6 Chapter 1. Introduction and Background

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

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

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

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

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

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

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

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

habitats and wildlife populations that existed during historic conditions.” 

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

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

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

Additionally, the Administration Act identifies six wildlife-dependent recreational uses for the 

Refuge System. These uses are hunting, fishing, wildlife observation and photography, and 

environmental education and interpretation. Under the Administration Act, the Service is to grant 

these six wildlife-dependent public uses, when compatible, special consideration in the planning for, 

management of, and establishment and expansion of units of the Refuge System. The overarching 

goal of the wildlife-dependent public use programs is to enhance opportunities and access to quality 

wildlife-dependent visitor experiences on refuges while managing refuges to conserve fish, wildlife, 

plants, and their habitats. When determined compatible on a refuge-specific basis, these six uses 

assume priority status among all uses of the refuge in question. The Service is to make extra efforts 

to facilitate priority wildlife-dependent public use opportunities. 

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

economic uses (even those occurring to further refuge habitat management goals) 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 the refuge purposes, the Refuge System mission, or goals or 

objectives described in an approved refuge management plan. A compatible use is a use that, in the 

sound professional judgment of the refuge manager, will not materially interfere with or detract from 

the purpose(s) of the refuge or the fulfillment of the Refuge System. Updated appropriate use 

findings and compatibility determinations for existing and planned uses for Rose Atoll NWR are in 

Appendices B and C of this CCP, respectively. 

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

must be developed with the participation of the public. Issues and concerns articulated by the public 

play a role in guiding alternatives considered during the development of the CCP, and together with 

the formal guidance, can play a role in selection of the preferred alternative. It is Service policy that 

CCPs are developed in an open public process and that the Service is committed to securing public 

input throughout the process. Appendix J of the CCP details public involvement that has been 

undertaken during this CCP process. 

1.2.5 Presidential Proclamation 8337

On January 6, 2009, President George W. Bush signed Presidential Proclamation 8337, designating 

the Rose Atoll Marine National Monument (Monument) which included the Rose Atoll NWR. The 

President directed that the Secretary of the Interior shall have management responsibility for the 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Chapter 1. Introduction and Background 1-7 

Monument, including the Refuge, in consultation with the Secretary of Commerce, except that the 

Secretary of Commerce, through the National Oceanic and Atmospheric Administration (NOAA), 

shall have the primary management responsibility regarding the management of the marine areas of 

the Monument seaward of mean low water, with respect to fishery-related activities regulated 

pursuant to the Magnuson-Stevens Fishery Conservation and Management Act (16 U.S.C. 1801 et 

seq.; MSFCMA), and any other applicable authorities. On January 16, 2009, Secretary of the Interior 

Kempthorne issued Secretarial Order 3284, delegating all his responsibilities for the Monument to 

the Service Director, and directed that the Refuge continue to be managed consistent with the 

Proclamation and within boundaries set forth in the Notice of Establishment, 71 FR 13183 (April 5, 

1974). 

Additionally, the President directed the Secretary of Commerce to initiate the process to add the 

marine areas of the Monument to the National Marine Sanctuary of American Samoa (NMSAS) in 

accordance with the National Marine Sanctuaries Act (16 U.S.C. 1431 et seq.). This process was 

concluded in 2012. This Rose Atoll NWR CCP is a separate plan for the conservation of the Refuge 

area only. 

1.2.6 Other Laws and Mandates

Many other Federal laws, Executive orders, Service 

policies, and international treaties govern the 

Service and Refuge System. Examples include the 

Migratory Bird Treaty Act of 1918 (MBTA), 

Refuge Recreation Act of 1962, National Historic 

Preservation Act of 1966 (NHPA), and the 

Endangered Species Act of 1973 (ESA). 

In addition, over the last few years, the Service has 

developed or revised numerous policies and 

Director’s Orders to implement the mandates and 

intent of the Administration Act. Some of these key policies include BIDEH; Refuge Compatibility 

(603 FW 2); Comprehensive Conservation Planning (602 FW 3); Mission and Goals and Refuge 

Purposes (601 FW 1), Appropriate Refuge Uses (603 FW 1); Wildlife-Dependent Public Uses (605 

FW 1-8); Wilderness Stewardship policies (610 FW 1-5), and the Director’s Order for Coordination 

and Cooperative Work with State/Territorial Fish and Wildlife Agency representatives on 

management of the Refuge System. 

In developing a CCP, we must consider these broader laws and policies as well as Refuge System 

and ecosystem goals and vision. The CCP must be consistent with these and also with the refuge 

purpose(s). For Rose Atoll NWR, specific examples of these broader laws include: 

• ESA;

• MBTA;

• Clean Water Act; 

• Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA); and the 

• MSFCMA (all waters and substrates, including corals, at Rose Atoll are identified as 

Essential Fish Habitat).

Sunset Butterfly Fish. Mark MacDonald/ASG-DMWR
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

1-8 Chapter 1. Introduction and Background

1.3 Refuge Establishment and Purposes

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

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

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

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

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

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

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

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

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

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

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

1.3.1 Refuge Establishment

Rose Atoll is part of the Territory of American Samoa and was established as a National Wildlife 

Refuge by cooperative agreement between the Government of American Samoa and the Bureau of 

Sport Fisheries and Wildlife (a predecessor of the U.S. Fish & Wildlife Service) on August 24, 1973. 

The establishment authority for the Refuge is the Fish and Wildlife Act of 1956, as amended. 

1.3.2 Purpose

The purposes for Rose Atoll NWR are “... for the development, advancement, management, 

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

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

services...” 16 U.S.C. § 742f(b)(1) (Fish and Wildlife Act of 1956, 16 U.S.C. §742(a)-754, as 

amended). 

1.3.3 Land Status and Ownership

Rose Atoll is managed by the Service in cooperation with the ASG as a National Wildlife Refuge 

under a cooperative agreement with the Government of American Samoa. The American Samoa 

Legislature (Fono) officially approved of the cooperative agreement with the passage of Senate 

Concurrent Resolution No. 14 in August 1973 (see Appendix K). Per Presidential Proclamation 

4347, the U.S. government maintains jurisdiction over the submerged lands and waters of the atoll 

and surrounding territorial seas. 

The exterior boundary of the Refuge is the extreme low waterline outside the perimeter reef, except 

at the entrance ava where the boundary is a line extended between the extreme low waterlines on 

each side of the entrance ava (Figure 1-2, page 1-9). 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Chapter 1. Introduction and Background 1-9 

Figure 1-2. Refuge overview and land status.
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

1-10 Chapter 1. Introduction and Background

The back sides of maps are blank to improve readability. 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Chapter 1. Introduction and Background 1-11

1.4 Refuge Goals

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

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

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

The Rose Atoll NWR vision is described on the inside front cover of this document. A vision broadly 

reflects refuge purposes, Refuge System mission and goals, other statutory requirements, and largerscale plans as appropriate. Goals 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 following are our 

goals in both Samoan and English language versions. 

Manulautī o le Faasao mo Meaola

1. Puipuia ma toe faaleleia nofoaga ‘ainā i le aloalo ina ia o gatasi ma tulaga moomia na iai ituaiga 

olaga faamauina o meaola eseese i lea lotoifale. 

2. Fa’afo’isia, puipui, ma toe faaleleia le si’omaga e ola ai le ituaiga limu e ta’ua o le “crustose 

coralline algae” i le a’au ina ia ‘ausia tulaga moomia tau le faaolaolaga o meaola i ituaiga eseese o lo 

o i lea itulagi.

3. Puipui ma toe faaleleia foliga ma tulaga masani o le ava e puipuia uma isi nofoaga ua ‘ainā e 

meaola o le Faasao ma le aafia o le pala mātū ona o le fogāsami o lo o si’omia ai le aloalo.

4. Fa’afo’isia, puipui, ma toe faaleleia le gataifale o lo o fai ma nofoaga o meaola o lea si’omaga ina 

ia o gatasi ma tulaga moomia na iai se ituaiga olaga faamauina o meaola eseese i lea lotoifale. 

5. Fa’afo’isia, puipui, ma toe faaleleia nofoaga o lo o folasia i le oneone o le gataifale ina ia o gatasi 

ma tulaga moomia na iai se ituaiga olaga faamauina o meaola eseese i lea lotoifale e aofia ai laau, 

manufelelei o le sami, manufelelei e masani ona aumau i le nofoaga oneonea o le matafaga, 

manufelelei o le laueleele, manufelelei e aumau i se vai o i le laueleele, o ituaiga manu fetolofi e i le 

faatulagaga e faaperetania o “reptiles”, ma pa’a e maua i le pala 

mātū. 

6. Faamaopoopo faamatalaga faasaienitisi (faamaumauga tau 

tamaoaiga, vaavaaiga o le itu i fafo ma totonu, laulilīuga, ma 

su’esu’ega) e lagolagoa fa’ai’uga fai a le taupulega e pei ona folasia 

mai e manulauti 1-5. 

7. Fa’atāua le faatoetoe o alagaoa ma opogi faatasi le faiva 

faatausimea e va’ava’alua ai ma tagata lautele e tusa ai o le 

si’osi’omaga o meaola uma, su’esu’ega tau le eleele, ma le tele o le 

tamaoaiga fa’aleaganu’u o le Faasao e ala i le faafoega o 

polokalama e feso’ota’i atu ai ma tagata lautele, o galuega tau 

faaliliu upu, ma a’oa’oga tau le si’osi’omaga. 

8. Faailoa ma’oti, puipui, faatoetoe, ma faaliliu tulaga tau alagaoa 

fa’aleaganu’u o le Faasao ma faafaigofie, pe a talafeagai ai, 

faagaoioiga fa’aleaganu’u. Fua'o. Frank Pendleton/USFWS
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

1-12 Chapter 1. Introduction and Background

Refuge Goals

1. Protect and maintain the lagoon habitats to meet the life-history needs of native species in this 

community. 

2. Restore, protect, and maintain the perimeter crustose coralline algal reef to meet the life-history 

needs of native species in this community.

3. Protect and maintain the natural state of the ava (channel) to protect all other Refuge habitats and 

the hydrology of the lagoon. 

4. Restore, protect, and maintain the beach strand habitat to meet the life-history needs of native 

species in this community. 

5. Restore, protect, and maintain littoral forest to meet the life-history needs of native species in this 

community including plants, seabirds, shorebirds, land birds, waterbirds, reptiles, and land crabs. 

6. Gather scientific information (inventories, monitoring, assessments, and research) to guide 

adaptive management decisions in support of Goals 1-5. 

7. Strengthen resource conservation and the public’s shared stewardship of the ecological, geologic, 

and cultural richness of the Refuge by providing outreach, interpretation, and environmental 

education opportunities. 

8. Identify, protect, preserve, and interpret the Refuge’s Samoan cultural resources and, where 

appropriate, facilitate cultural practices. 

1.5 Relationship to Other Planning Efforts

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

regional, State/Territorial, and ecosystem plans and/or assessments. The CCP is expected to be 

consistent, as much as possible, with existing plans and assist in meeting their conservation goals and 

objectives (602 FW 3). This section summarizes some of the key plans reviewed by members of the 

core team while developing this CCP. 

Final Restoration Plan for Rose Atoll National Wildlife Refuge (USFWS and DMWR 2001). The 

Jin Shiang Fa fishing vessel ran aground on the western reef of the atoll in 1993 and broke up before 

a salvage tug could reach the atoll, resulting in the release of over 100,000 gallons of diesel and lube 

oil across the reef killing a large area of CCA near the wreck site. Invasive species of cyanobacteria 

and articulated coralline algae immediately began colonizing those areas of the reef. This plan 

covered removal of vessel debris and monitoring the recovery of the injured reef community. 

Recovery Plan for U.S. Pacific Populations of the Green Turtle (NMFS and USFWS 1998a). The 

green turtle 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 green turtles 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. Human development is also having an increasingly serious impact on nesting beaches. 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Chapter 1. Introduction and Background 1-13

Recovery Plan for U.S. Pacific Populations of the Hawksbill Turtle (NMFS and USFWS 1998b). 

The Hawksbill turtle is listed as endangered throughout its range. Threats to these turtles include 

harvest of species for meat, eggs, and the tortoiseshell and stuffed curio trade and increasing human 

populations and subsequent destruction of habitat. Actions identified to recover the species include 

addressing harvesting and development threats, reducing incidental mortalities by commercial and 

artisanal fisheries, better surveying and monitoring, supporting management in areas that have 

existing populations, identifying stock home ranges and primary nesting and foraging areas, and 

controlling nonnative predators. 

U.S. Pacific Islands Regional Shorebird Conservation Plan (Engilis and Naughton 2004). 

Conservation and restoration of shorebird habitats is essential for the protection of endangered and 

declining shorebird populations. Monitoring and research needs include assessment of population 

sizes and trends; assessment of the timing and abundance of birds at key wintering and migration 

stopover sites; assessment of habitat use and requirements at wintering and migration areas; 

exploration of the geographic linkages between wintering, stopover, and breeding areas; and 

evaluation of habitat restoration and management techniques to meet the needs of resident and 

migratory species. Education and public outreach are 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. 

1.6 Planning and Issue Identification

1.6.1 Issues Addressed in the CCP

The planning process for the CCP is described in detail in Appendix J. Summary of Public 

Involvement. The following key issues were identified in the planning process: 

Wildlife and Habitat Resources: How can habitat and species management be improved? How can 

we maximize the ability of habitats and species to adapt and resist effects of climate change and 

ocean acidification? What are our priority research and survey needs to support management? 

Cultural/historic resources: How is Rose Atoll connected to Samoan culture and what is its 

significance? How can we facilitate and support cultural connections to Rose Atoll? How can they be 

woven together with public interpretation? How can historic resource management be enhanced? 

Visitor services and wildlife-dependent recreation: What are appropriate and compatible uses in 

relation to on-site levels of environmental education and interpretation? 

Law enforcement: How can trespass, illegal activity, and human-caused disturbance to wildlife be 

managed more effectively given limited personnel and remoteness of the Refuge? 

1.6.2 Issues outside the Scope of the CCP

Management of the Monument: While CCPs are very comprehensive plans, no single plan can 

cover all issues. Management of the Monument is complex, with two Federal agencies (the Service

and NOAA) and two Government of American Samoa Territorial departments (Department of 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

1-14 Chapter 1. Introduction and Background

Commerce (ASDOC) and Department of Marine and Wildlife Resources (DMWR)) working 

together. The Secretary of the Interior through the Service has management responsibility for the 

Monument, including Rose Atoll NWR. However, the Secretary of Commerce, through NOAA 

NMFS has primary management responsibility regarding the management of the marine areas of the 

Monument seaward of mean low water, with respect to fishery-related activities. Additionally, the 

area in the Monument excluding the Refuge is part of the National Marine Sanctuary of American 

Samoa.

Fishing: Commercial fishing is prohibited in the Monument according to the Proclamation and all 

fishing is prohibited within 12 nautical miles (nmi) of the Refuge. Non-commercial fishing is 

allowed in the Monument outside of the 12 nmi no-fishing zone. Non-commercial fishing includes 

subsistence fishing and recreational fishing. The prohibition on all fishing within 12 nmi of the 

Refuge will be reviewed by the Western Pacific Regional Fisheries Council and NOAA’s National 

Marine Fisheries Service (NMFS) in 2016. Additionally, the areas of the Monument that are outside 

of the Refuge became part of the National Marine Sanctuary of American Samoa in 2012. In 

developing and implementing any management plans, the Secretaries of the Interior and the 

Commerce shall involve as cooperating agencies the agencies with jurisdiction or special expertise, 

including the U.S. Department of Defense, U.S. Department of Commerce, and other agencies, 

through scoping in accordance with National Environmental Policy Act (42 U.S.C. 4321 et seq.; 

NEPA), its implementing regulations, and with Executive Order 13352, and shall treat as a 

cooperating agency the American Samoa Government through the DMWR and ASDOC consistent 

with the above authorities. 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Chapter 2. Refuge Management Direction 2-1 

Chapter 2. Refuge Management Direction 

2.1 Overview 

During development of the CCP, the Service reviewed and considered a variety of resource, social, 

economic, and organizational aspects important for managing the Refuge. As is appropriate for a 

national wildlife refuge, resource considerations were fundamental in designing alternatives. 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.” American 

Samoa and Federal agencies, elected officials, local villages, and non-profit organizations were 

contacted by the planning team to ascertain priorities and problems as perceived by others. Public 

scoping in American Samoa occurred during 2009 and over 60 people participated in the public 

meetings. This helped us to further identify issues and priorities. Further details of public 

involvement and participation can be found in Appendix J. 

2.2 General Guidelines

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

descriptions for individual strategies, common features are presented below. 

Implementation subject to funding availability. After the CCP is completed, actions will be 

implemented over a period of 15 years as funding becomes available. Project priorities and projected 

staffing/funding needs are included in Appendix D. 

Tava’e’ula (red-tailed tropicbird). Kelsie Ernsberger/USFWS
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

2-2 Chapter 2. Refuge Management Direction

Access. The Refuge is closed to general public use and access in accordance with the Administration 

Act. The specific planned uses of the Refuge are described in Appendices B and C. Specific requests 

to access the Refuge associated with planned uses will be evaluated on a case-by-case basis and 

authorized through issuance of a Refuge Special Use Permit (SUP) by the Refuge/Monument 

Manager.

Biosecurity measures. Refuge visitation protocols will continue to include strict biosecurity 

measures to prevent nonnative introductions (e.g., rats, ants, scale insects, etc.) and impacts from 

reactive materials (e.g., iron). Anyone entering the Refuge for management activities or under SUP 

will be required to follow the written aquatic and terrestrial quarantine procedures used for all 

uninhabited refuges in the Pacific Reefs NWRC. Restrictions are designed to remove or kill pest 

species that may be in clothes or gear before they are taken to the Refuge. Additional information can 

be found in Appendix L (Best management practices for visitors to Rose Atoll). 

Threatened and Endangered Species Protection and Recovery. Protection of threatened and 

endangered species is common across all alternatives. It is Service policy to give priority 

consideration to the protection, enhancement, and recovery of these species on national wildlife 

refuges. The protection of federally listed species is mandated through the Endangered Species Act 

of 1973 (ESA). Section 7 of the ESA, called "Interagency Cooperation," is the mechanism by which 

Federal agencies ensure the actions they take, including those they fund or authorize, do not 

jeopardize the existence of any listed species. To ensure adequate protection, the Refuge is required 

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

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

an endangered species, then the Refuge conducts a formal review, known as a consultation, to 

identify those effects and means to mitigate those effects.

Cultural and historic resource protection. Cultural and historic resources on refuges 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. Actions with the potential to affect cultural and historic resources will 

undergo a thorough review before being implemented, as is consistent with the requirements of 

cultural resource laws. All ground-disturbing projects will undergo a review (including but not 

limited to archaeological and cultural surveys) under Section 106 of the NHPA. The Service will 

provide our 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. We will also coordinate and consult 

with the American Samoa Historic Preservation Office (ASHPO) and the Office of Samoan Affairs 

(OSA) and seek assistance from the Manu’a people on issues related to cultural resource education 

and interpretation, special programs, and the NHPA. We will expand Refuge cultural resource 

management by working with the ASHPO, OSA, and other partners to conduct archaeological 

surveys at Rose Atoll, integrate cultural resources into interpretation and environmental education 

(EE), and improve dialogue with Manu’a villages. We will also work with local officials to facilitate 

appropriate cultural practices.

Law enforcement. The service will continue to work with NOAA to identify the Refuge on U.S. 

nautical charts and other official marine information products. To deter ship groundings, we will 

develop targeted outreach materials and work within the international maritime community (e.g., 

International Maritime Organization), through appropriate U.S. agencies, to designate the Refuge as 

“area to be avoided.” Also, the Service will reinstall signage at the Refuge and improve outreach 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Chapter 2. Refuge Management Direction 2-3 

materials to educate the sailing community that the Refuge is closed. This information will be made 

available to yachtsmen and other mariners at regional embarkation points (e.g., harbors in Samoa and 

French Polynesia). These points are where boaters may depart from, en route to other destinations, 

and may pass by the Refuge. 

Adaptive management. Based on 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 Title 43 of 

the 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). Adaptive management 

accounts for the fact that complete knowledge about fish, wildlife, 

plants, habitats, and the ecological processes supporting them may 

be lacking. Adaptive management emphasizes learning while doing 

based upon available scientific information and best professional 

judgment considering site-specific biotic and abiotic factors on 

refuge lands and waters. Part of measuring the success of adaptive 

management in the Refuge also includes 5-year reviews and a 15-

year revision of the CCP, which will be initiated by the Service. 

Integrated pest management (IPM). In accordance with 517 DM 1 and 569 FW 1, an IPM 

approach will be used, where practicable, to eradicate, control, or contain pest and invasive species 

(herein collectively referred to as pests) on refuges. IPM will involve using methods based upon 

effectiveness, cost, and minimal ecological disruption, which considers minimum potential effects to 

non-target 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 is needed on refuge lands or waters, the most 

specific (selective) chemical available for the target species will be used unless considerations of 

persistence or other environmental and/or biotic hazards would preclude it. In accordance with 517 

DM 1, pesticide usage will be further restricted because only pesticides registered with the U.S. 

Environmental Protection Agency (EPA) in full compliance with FIFRA and as provided in 

regulations, orders, or permits issued by EPA may be applied on lands and waters under refuge 

jurisdiction. 

Environmental harm by pest species refers 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 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; killing their young or preventing them from 

reproducing; out-competing 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 seabird reproduction may result from a pest killing native plants that provide nesting 

habitat. 

Environmental harm may involve detrimental changes in ecological processes. For example, 

cyanobacterial infestations can inhibit the growth of CCA which is a very important reef builder. 

Tava’e’ula chick. Tracy Hart/USFWS
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

2-4 Chapter 2. Refuge Management Direction

This can lead to a situation where reef growth does not keep up with reef erosion, lowering the reef 

elevation and threatening the islands with ocean inundation. Environmental harm may also cause or 

be associated with economic losses and damage to human, plant, and animal health. Predator 

management is aimed at minimizing entry of nonnative predators using quarantine protocols, 

exclusion, habitat modification, control, and eradication. For example, live trapping and use of bait 

stations could be used to eradicate illegally introduced rats and mice. Predator and pest management

will be conducted by Service personnel or contractors. 

See Appendix G for the Refuge’s IPM program documentation to manage pests for this CCP. Along 

with a more detailed discussion of IPM techniques, this documentation describes the selective use of 

pesticides for pest management on refuges, where necessary. Throughout the life of the CCP, most 

proposed pesticide uses on the Refuge will be evaluated for potential effects to biological resources 

and environmental quality. Pesticide uses with appropriate and practical best management practices

for habitat management will be approved for use where there likely will be only minor, temporary, 

and localized effects to species and environmental quality based upon non-exceedance of threshold 

values in Chemical Profiles. However, pesticides may be used where substantial effects to species 

and the environment are possible (exceed threshold values) in order to protect human health and 

safety. 

Outreach, interpretation, and environmental education (EE). Refuge staff will provide outreach 

and interpretation opportunities and develop an EE program for American Samoa schools. We will 

develop programs to inform elected officials, students, and the general public of American Samoa 

about the ecology of Rose Atoll and the mission of the Service. We will work closely with our 

partners to develop complementary interpretive displays for visitor centers. 

Partnerships. Partnerships are critical components in refuge management, including maintaining 

and restoring resources, conducting inventories and surveys, providing for cultural uses, and 

coordinating education and outreach opportunities. These important partnerships typically involve 

joining forces with the ASG as well as other Monument partners, other Federal partners, villages, 

businesses, and non-governmental organizations in meeting common mission objectives. Some 

current examples of valued partnerships the Service will maintain include:

The Service will maintain regular discussions with the ASG to coordinate management of the 

Refuge. The Service will work with the DMWR to continue research, monitoring, education, 

outreach, interpretation, law enforcement, and management activities at the Refuge. We will continue 

to work with the Office of Samoan Affairs (OSA) to facilitate and maintain appropriate relationships 

with people in the villages in Manu’a and Tutuila. The Service will also keep the ASDOC and the 

DMWR informed of activities through regular discussions and common forums such as the Coral 

Reef Advisory Group and the Rose Atoll Marine National Monument Intergovernmental Committee. 

The Service will maintain its partnership with NOAA through its National Ocean Service, NMFS’s

Marine National Monument Program (MNMP), and Pacific Islands Fisheries Science Center (PIFSC) 

and its Coral Reef Ecosystem Division (CRED). The CRED provides intensive oceanography, water 

quality, habitat, biological population, and acoustic data as well as benthic habitat mapping as part of 

their Reef Assessment Monitoring Program (RAMP). The RAMP missions to the Refuge took place

every 2 years between 2002-2012; however, due to decreased funding, NOAA has scaled back 

missions to every 3 years after 2012. The most recent CRED trip to Rose occurred in 2012, with the 

next one scheduled in 2015. The Service has also worked closely with DMWR since the creation of 

the Refuge for conducting biological monitoring and habitat restoration projects. The Service will 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Chapter 2. Refuge Management Direction 2-5 

also maintain its partnership with the U.S. Coast Guard (USCG). The USCG has provided a law 

enforcement presence by having vessels patrol the area, and through overflights of the Refuge. 

Additionally we have partnerships with the National Park Service (NPS), Office of National Marine 

Sanctuaries (ONMS), U.S. Geological Survey, and the ASDOC. NPS provides the Service office 

space and will assist with biological monitoring and habitat restoration projects in the future. We will 

also work closely with NPS on interpretation, EE, and outreach (e.g., Refuge display in their visitor

center). Management of the Monument involves many partners. The Service has management 

responsibility for the Monument in consultation with NMFS. Additionally, the Muliava Unit of the 

National Marine Sanctuary of American Samoa overlays the marine areas of the Monument outside 

of the Refuge. The Service is building a partnership with ONMS and ASDOC regarding management 

of the Sanctuary/Monument overlay area. 

Response capacity. Within 5 years, we will create response capacity to minimize trespass and 

poaching using outreach, education, remote sensing, law enforcement, and other methods (e.g., 

evaluate the possibility of enforcement officers from American Samoa patrolling the Refuge, 

formalize partnership with USCG for surveillance). 

Vessel. The Service will seek to acquire a vessel, part ownership in a vessel, or long-term vessel 

charter contract to assist with management actions, law enforcement, and monitoring.

Wildlife and habitat. Implementing the CCP’s management direction will enhance protection and 

management of resources with improved monitoring, law enforcement, and an enhanced 

understanding of the atoll. More frequent visits (at least twice annually) will allow for the collection 

of year-round data which will aid management decisions, improve information for law enforcement 

(e.g., documentation of unauthorized entry into the Refuge), and provide a presence to deter illegal 

activity. A remote sensing system (e.g., automated camera) will be set up to monitor nesting 

seabirds, turtles, and other wildlife. 

We will explore restoration of the littoral forest on Rose Island by extirpating the introduced scale 

insect (Pulvinaria urbicola) and propagating native forest trees. Other pest species will be detected 

and controlled or eradicated with regular monitoring and a rapid response program. We will continue 

the restoration effort from the 1993 ship grounding through consistent surveying of the wreck site, 

removal of any debris, and continued monitoring. 

Young pu’a vai. Frank Pendleton/USFWS
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

2-6 Chapter 2. Refuge Management Direction

Table 2-1. Summary of Management Direction 

Key Themes Objectives Management Direction 

Lagoon Habitat 1.1 Protect and 

maintain the lagoon 

habitats 

Work with partners to continue collecting data on 

bathymetry, water quality, and species diversity. 

Develop and implement monitoring protocols for fish, 

corals, other invertebrates, and marine pests to manage 

populations as needed. Install remote sensing system

(e.g., camera) to monitor resources and document 

illegal boat traffic.

Perimeter Reef 2.1 Restore, protect, 

and maintain the 

perimeter reef 

Monitor cyanobacterial cover which greatly increased 

in response to the 1993 shipwreck, continue to remove 

debris. Continue and expand reef monitoring program. 

Ava 3.1 Protect and 

maintain the ava

Work with partners to continue collecting data on 

water flow and bathymetry. Survey for predator and 

prey fish species. 

Beach Strand 4.1 Restore, protect, 

and maintain the 

beach strand 

Restore tamole (Portulaca lutea). Prepare and 

implement a monitoring plan and rapid response 

program for terrestrial nonnative species.

Littoral Forest 5.1 Restore, protect, 

and maintain littoral 

forest 

Monitor seabirds and control niu (Cocos nucifera). 

Restore native littoral forest and improve monitoring 

of seabirds, vegetation, and pest species. 

Inventory, 

Monitoring, and 

Research

6.1 Conduct high 

priority inventory and 

monitoring (survey) 

activities and scientific 

assessments

Work with partners to continue monitoring water 

quality, bathymetry, species distribution, and habitat 

associations. Improve the quality and quantity of 

monitoring efforts by monitoring more often, creating 

standardized protocols, and management databases.

6.2 Conduct high 

priority research 

Increase research as part of restoration efforts for 

habitats and wildlife populations. 

Outreach, 

Interpretation, 

and 

Environmental 

Education (EE) 

7.1 Enhance and 

expand interpretation 

and outreach 

Maintain website. Participate in community events.

Develop more interpretive opportunities with our 

partners. 

7.2 Develop EE Develop an EE program. 

Cultural 

Resources

8.1 Protect and 

perpetuate cultural 

resources related to 

Rose Atoll 

Work with partners to create information materials. 

Inventory, restore, and maintain cultural resources and 

work with local representatives to facilitate appropriate 

cultural traditions related to Rose Atoll, and regularly 

meet with OSA and Manu’a village councils
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Chapter 2. Refuge Management Direction 2-7 

Figure 2-1. Management direction. 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

2-8 Chapter 2. Refuge Management Direction

The back sides of maps are blank to improve readability.
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Chapter 2. Refuge Management Direction 2-9 

2.3 Rose Atoll NWR Management

Goals, objectives, and strategies are the unifying 

elements of successful refuge management. They 

identify and focus management priorities, resolve 

issues, and link to refuge purposes, Service policy, 

and the Refuge System mission. The goals for the 

Refuge are presented on the following pages 

followed by the objectives that pertain to it. Some 

objectives pertain to multiple goals and have simply 

been placed in the most appropriate spot. Similarly, 

some strategies pertain to multiple objectives. The 

goal order does not imply any priority in this CCP.

Priority actions are identified in the staffing and 

funding analysis (see Appendix D). 

Readers, please note the following: Below each objective statement are the strategies that could be 

employed in order to accomplish the objectives. Symbols used in the following tables include:

~ Approximately; 

% Percent; 

> Greater than; 

< Less than; 

> Greater than or equal to; and

< Less than or equal to. 

2.3.1 Goal 1. Protect and maintain the lagoon habitats to meet the life-history 

needs of native species in this community. 

Objective 1.1 Protect and maintain the lagoon habitats. 

Protect and maintain lagoon reef habitats to provide the following attributes: 

• 547 acres of shallow (<100 feet) water lagoon habitat to meet life-history requirements of 

all existing native members of the lagoon community. See Appendix A for species listings;

• Natural flow of marine water with quality measures of pH, salinity, temperature, nutrients, 

chlorophyll-a, that are appropriate to maintain native organisms in the lagoon community; 

• Benthic bottom cover of sand interspersed with patch reefs, limestone blocks, and pinnacles 

providing a variety of substrates and rugose structure to provide habitat for lagoon species;

• Species diversity including algae, fish, turtles, and invertebrates including reef-building 

corals and reef-building crustose coralline algae; 

• Lagoon free of debris; and

• Minimal human disturbance.

Goatfish in lagoon. Jim Maragos/USFWS
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2-10 Chapter 2. Refuge Management Direction

Strategies Applied to Achieve Objective

Work with partners to collect bathymetry data every 10 years in order to document changes in the 

lagoon, reef, or ava that could affect hydrography or habitat characteristics 

Work with NOAA’s CRED and other partners to collect oceanographic and water quality data in 

order to track changes that could affect the reef or wildlife 

Work with partners to conduct Rapid Ecological Assessment (REA) to document habitat 

associations and species distribution, density, and diversity in marine habitats 

Identify, prioritize, and implement restoration needs such as debris removal in lagoon habitats 

affected by anthropogenic impacts such as iron contamination from shipwrecks 

Within 5 years, develop and implement monitoring protocols to track populations of focal lagoon 

species, including fish, corals, faisua, other invertebrates, and marine pests to determine abundance, 

density, and biomass of each at selected sites 

Within 10 years, characterize nutrient budgets and dynamics at Rose Atoll and evaluate them 

relative to data from other similar reef sites to identify possible stressors and the positive effects of 

healthy seabird colonies adjacent to living reefs 

Within 4 years, install remote sensing system (e.g., camera) to document boat traffic in the lagoon 

Rationale: In the middle of an ocean that is mostly over 10,000 feet deep, the lagoon provides 547 

acres of shallow water habitat (< 100 feet deep). The reef protects this lagoon from the large swells 

of the open ocean, and light is able to penetrate to the bottom so corals and other sea life can thrive. 

While the deepest part of the lagoon has a simple sand bottom, sections on the edge have coral 

pinnacles which grow up close to the surface providing excellent habitat for faisua (Tridacna 

maxima). This shallow lagoon hosts a unique assemblage of fish and the largest population of faisua 

in American Samoa. These faisua are listed under the Convention on International Trade in 

Endangered Species (CITES) and have suffered serious depletion throughout their range due to 

over-harvesting. While it can provide larval fish recruitment for the other Samoan Islands, the small 

size of the lagoon and its limited fish and invertebrate community make it particularly susceptible to 

fishing pressure. 

Monitoring fish and invertebrate abundance and biomass as well as abiotic factors is critical so we 

can assess whether the Service is maintaining BIDEH of the lagoon (see Goal 6). Monitoring is key 

to refining the metrics in the attributes (which currently reflect how little is known at present about 

this habitat). Ongoing restoration efforts emphasize removal of debris and monitoring the 

cyanobacteria bloom. A remote sensing system (e.g., camera) will document unauthorized boat 

traffic in the lagoon since such traffic could involve unregulated fishing or damage other Refuge 

resources. 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Chapter 2. Refuge Management Direction 2-11

2.3.2 Goal 2. Restore, protect, and maintain the perimeter crustose coralline 

algal reef to meet the life-history needs of native species in this community.

Objective 2.1 Restore, protect, and maintain the perimeter crustose coralline algal reef. 

Restore, protect, and maintain the perimeter crustose coralline algal reef to support habitats and 

species with the following attributes:

• Healthy living reef dominated by CCA (Porolithon spp.) in a mosaic with corals forming a 

network of pools and raised areas that provide habitat for reeftop organisms; 

• Geomorphic structure intact with elements of rugosity and a mosaic of microhabitats;

• Tuitui (boring sea urchins / Echinometra, Echinostrephus spp.) are present in at least 50% 

of available holes along the entire seaward margin of the perimeter reef; 

• Holes that can be occupied by tuitui are present at a density of at least 1/m2 in the “urchin 

zone” along the entire seaward margin of the perimeter reef; 

• CCA are present in 80% of sampling sites and occupy >25% of total solid substratum; 

• Cyanobacteria (Lyngbya, Oscillotoria, Symploca, Calothrix spp.) are rare (<5% total cover); 

• The erect coralline alga Jania adherens, and the mat-forming green alga Codium spp., are 

rare (i.e., present in < 5% of sample sites); 

• CCA characterized as eroded is not a prominent cover type and the proportion of this type 

does not fluctuate significantly between surveys; 

• Variation in cover of CCA is primarily due to reef position (i.e., fore, mid, or inner reef), 

• reflecting the wave energy and structural gradients across the reef flat; and 

• 100% removal of manmade debris including fishing gear and metallic debris from 

shipwrecks. 

Strategies Applied to Achieve Objective 

Continue monitoring abundance and distribution of the cyanobacterial community 

Within 5 years, work with partners to continue and expand the reef monitoring program, including 

rate of growth, elevation change, chemical composition and other variables related to reef growth 

and the atoll’s ability to maintain itself in an anticipated environment of climate change and ocean 

acidification 

Within 5 years, develop and implement monitoring protocols to track abundance and distribution of 

focal perimeter reef species including eels and urchins to determine abundance, density, and 

biomass of each at selected sites 

Monitor benthic succession of the reef which was damaged due to the 1993 shipwreck 

Within 2 years, establish systematic marine debris removal program 

Rationale: The reef crest of Rose Atoll has a pink hue because it is primarily composed of CCA. It varies 

between 1,000–3,000 feet wide and has a single ava connecting the inner lagoon with the open ocean. 

Waves can break hard over the reef crest, but during low tides it can be completely exposed. Several of 

the dominant species of algae on this reef (Porolithon onkodes, P. craspedium, and P. gardineri) are reefbuilding organisms that form a strong and resilient reef platform upon which all the other shallow water 

organisms depend. Two other cover types on the reef platform are a coralline red algae Jania spp. that 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

2-12 Chapter 2. Refuge Management Direction

forms turfs rather than a crust, and areas of eroded and dead coralline algae that are bare reef matrixes 

without macroscopic algae present.

In 1993 a fishing vessel ran aground on the southwest 

arm of the reef and broke apart. The vessel released 

roughly 100,000 gallons of fuel, 500 gallons of oil, 

and 2,500 pounds of ammonia into the environment. 

This killed a large area of CCA, and facilitated a 

population explosion of cyanobacteria and non-reef 

building algae. Major salvage operations began 6 

weeks after the wreck and continued until 2007 due to 

the large tonnage of metal and the difficulty of 

working on a remote atoll. The ship rocking back and 

forth in the waves physically damaged the reef by 

grinding it away. 

Because iron is a limiting nutrient at remote oceanic 

atoll locations, the increased iron levels led to a drastic increase in several species of cyanobacteria 

(Symploca spp., Oscillatoria spp., Lyngbia spp., and Calothrix spp.) and turf forming coralline algae near 

the shipwreck site. These species are not reef building organisms, and in places where they grow in thick 

mats, reef building corals and CCA cannot compete, so the reef can begin to erode. These cyanobacterial 

species initially formed a carpet, covering large sections of the reef near the wreck. It is vital to control 

them in order to maintain the reef. 

Though the vast majority of the ship has been removed and the area is recovering, there are likely 

scattered pieces on the fore reef continuing to release iron into the water and promoting the growth of 

cyanobacteria. This, combined with the acute effects of the initial spill and the physical destruction of the

reef by the ship, has seriously damaged the CCA near the shipwreck site and recovery efforts will be 

ongoing. It is vital to maintain the living coralline algae on these perimeter reefs because they form a 

growing platform that is resistant to physical and bio-erosion upon which all the shallow water and 

terrestrial organisms at the Refuge depend. The focal species of urchins serve as indicators of the 

state of the reef on areas least affected by the shipwreck and areas where subsequent urchin mortality 

resulted from spilled fuel and cyanobacterial overgrowth. Densities of peppered morays foraging on 

the reef flat also are an indication of the productivity and health of that habitat.

Grounded vessel. USFWS

Reef crest spillway. Jim Maragos/USFWS
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Chapter 2. Refuge Management Direction 2-13

2.3.3 Goal 3. Protect and maintain the natural state of the ava (channel) to 

protect all other Refuge habitats and the hydrology of the lagoon.

Objective 3.1 Protect and maintain the ava. 

Protect and maintain the natural state of the ava to support habitats and species with the following 

attributes:

• Unobstructed water flow between the lagoon and the ocean;

• Geomorphology that supports the hydrology of the atoll; and 

• Species diversity and biomass of reef builders and reef dwellers, including large predator 

and prey fishes, remains high. 

Strategies Applied to Achieve Objective: 

Within 5 years, work with partners to monitor water flow rate and direction in the ava using archival 

pressure and flow rate instruments that can be downloaded at every visit in order to document any 

changes in flow through the ava 

Work with partners to collect bathymetry data every 10 years in order to document changes in the 

lagoon, reef, or ava which could affect hydrography or habitat characteristics 

Within 5 years, develop and implement monitoring protocol to track abundance and biomass of fish, 

including predator and prey fish species, around the opening of the ava to detect any changes in 

structure or function of this important geological feature for large predators in the Refuge 

Work toward the inclusion of better warnings about the hazard to mariners of waters in and near the 

ava to prevent vessel groundings, and improve public communications about the Refuge being 

closed

Rationale: The ava is a small, direct connection between the lagoon and the open ocean. As ocean 

water spills into the lagoon over the sides of the reef, it is released out through the ava. Though 

water usually flows out the ava, tides and waves occasionally create a situation where water flows 

into the lagoon. The elevation of the ava controls the water movement out of the lagoon, and plays a 

major role in the layering of lagoon water by temperature and salinity. Additionally, the shape and 

location of the ava is an important factor in the location and longevity of the islands on the atoll. 

Water movement inside the atoll creates currents that remove sand from some areas and deposit it in 

other areas. This sediment transport regime has created and maintained Rose and Sand Islands as 

islands dynamic in size and shape but in roughly the same location since Captain Rantzau mapped 

Rose Atoll in 1873 (Rodgers et al. 1993). 

The ava is also the major passageway for fish and other organisms in and out of the lagoon, where 

species that require more shelter from rough water to breed or live may concentrate. Sharks and 

other predators congregate at the mouth of the ava waiting for prey. For these reasons, it is vital to 

protect and maintain the ava because it is fundamental to the functioning of many systems in Rose 

Atoll. Though there are currently no known threats to the ava and it is stable, given potential climate 

change impacts, constant alertness to changing conditions is important. As identified in Figure 1-2 

in Chapter 1, the ava where this work will occur is the exterior boundary of the Refuge where the 

boundary line is extended between the extreme low waterlines on each side of the channel.
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

2-14 Chapter 2. Refuge Management Direction

2.3.4 Goal 4. Restore, protect, and maintain the beach strand habitat to meet 

the life-history needs of native species in this community.

Objective 4.1 Restore, protect, and maintain beach strand habitat for shorebirds, groundnesting seabirds, and nesting turtles. 

Restore, protect, and maintain >3 acres of the beach strand on Sand and Rose Islands to support 

habitats and species with the following attributes:

• Open ground maintained, with native plants (e.g., tamole) occupying the edge between 

beach strand and littoral forest; 

• Free of terrestrial nonnative predators and other nonnative animals; and

• Free of pest and nonnative plants. 

Strategies Applied to Achieve Objective: 

Within 2 years, use GPS to map the perimeter of the islands at high and low tide on each visit to the 

Refuge and obtain any available satellite imagery for incorporation into GIS in order to document 

changes in island size, shape, and location 

Within 15 years, restore and protect native coastal plants using best available information about the 

original indigenous ecosystem. Restore native tamole (Portulaca lutea; a native yellow purslane) 

population that was extirpated on Rose Atoll by introduced rats (Rattus exulans) but survived on an 

offshore coral block. Monitor survivorship, growth, and maturation of planted tamole 

Within 10 years, investigate the ecological relationships between marine gastropods such as turban 

shells (Turbo spp.) and land hermit crabs (Coenobita perlatus and C. brevimanus). Evaluate factors 

affecting crab populations, including observed reduction in availability of shells to crabs at the 

Refuge and what management may improve mollusk shell availability to the Coenobita spp. which 

are important scavengers and herbivores on both islands 

Within 5 years, work with universities and other partners to evaluate the geomorphology, 

hydrology, and sediment budget of Rose Atoll to understand the processes that have maintained the 

islands as dynamic units 

Within 6 months, revise existing biosecurity measures to comprehensively address prevention of 

introducing nonnative pest species to the atoll

Within 2 years, prepare and implement a monitoring plan and rapid response program for terrestrial 

nonnative species and respond immediately if detected 

Within 2 years, working with NOAA/NMFS, DMWR, and other partners, develop and implement 

monitoring protocol to track turtle abundance and movements using field counts, tagging, remote 

sensing (e.g., camera), and satellite telemetry 

Within 5 years, working with NOAA/NMFS and other partners, develop a cooperative management 

plan with Fiji to protect shared stocks of threatened green turtles that migrate between Rose Atoll 

(to nest) and Fiji (to feed). Meet with appropriate Fiji managers as needed 

Rationale: Beach strand is a very dynamic habitat that is constantly being reshaped by the wind, 

waves, currents, and tides. Likely this will be exacerbated by climate change with more frequent 

storms, changes in sea level, and coral calcification. All of Sand Island can be classified as beach 

strand, as can the sandy section of Rose Island between the water and the vegetation. During a storm, 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Chapter 2. Refuge Management Direction 2-15

beach strand habitat can change dramatically, but when conditions are right, it reforms quickly and is 

stable in the long run. This is the case with the beach strand habitats of the Refuge. After any given 

storm the islands may change size and shape, but since the area was mapped by Rantzau in 1873 

(Rodgers et al. 1993) the location and total area of the islands has remained surprisingly stable. 

Because the Refuge provides beach strand habitat free of predators since the 1993 eradication of 

Polynesian rats (Rattus exulans) and is far from human populations, it is ideal foraging habitat for 

wintering shorebirds and nesting habitat for seabirds and i’a sa, and possibly hawksbill turtles. The 

beach strand is used extensively by nesting gogosina (sooty terns), gogo (brown noddies), fua’o 

(brown boobies), and i’a sa (green turtles). The Refuge provides the only known rat-free area in 

American Samoa for several of these ground-nesting species. Part of enhancing this habitat for these 

birds and fulfilling BIDEH is restoring previously extirpated plants such as the tamole, a rare plant 

that used to exist on the beach strand habitat. 

Ghost crabs (Ocypoda spp.) forage and dig their burrows in the beach strand as well. The land hermit 

crabs Coenobita perlatus and C. brevimanus are numerically and ecologically important in the 

terrestrial ecosystem of Rose Atoll, serving as the dominant herbivores and scavengers of the system. 

Densities of these two species have decreased markedly since 1991 and biologists visiting the Refuge 

have noticed a change in the condition and type of the marine gastropod shells that the crabs are 

using for their homes. There seem to be fewer of the preferred shells in the genus Turbo and those 

that are being used have more damage and wear. Substitutes such as the partridge tun (Tonna perdix) 

shells are more fragile and presumably offer less protection. 

Tagging data demonstrates that Rose Atoll and Fiji 

share a common stock of i’a sa. After nesting at 

Rose Atoll, the turtles tagged in the 1990s migrated 

directly to Fiji to feed on extensive seagrass beds 

there (there is little seagrass in American Samoa). A 

comprehensive recovery plan requires protection at 

both its nesting and feeding destinations of this 

species. While turtle harvesting is prohibited in Fiji, 

enforcement there is difficult due to the hundreds of 

small islands and remote villages, thus poaching is 

considered a serious threat. I’a sa are a threatened 

species with a very small population size at Rose 

Atoll (est. 24-36 nesting females). 

In order to maintain the beach strand as a naturally occurring dynamic habitat which benefits many 

species, we will control any plant or animal pest species, and monitor the size and shape of the 

islands to determine if they are maintaining themselves under changing climatic conditions.

Satellite tagged i'a sa. Frank Pendleton/USFWS
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

2-16 Chapter 2. Refuge Management Direction

2.3.5 Goal 5. Restore, protect, and maintain littoral forest to meet the lifehistory needs of native species in this community including plants, seabirds, 

shorebirds, landbirds, waterbirds, reptiles, and land crabs.

Objective 5.1 Restore, protect, and maintain littoral forest. 

Restore, protect, and maintain 15 acres of the littoral forest with the following attributes:

• Forest species composition includes a mixture of pu’a vai (Pisonia grandis), taukanave 

(Cordia subcordata), tausuni (Tournefortia argentea), fotulona (Hernandia nymphaeifolia), 

talie (Terminalia samoensis), fao (Neisosperma oppositifolium), fau (Hibiscus tiliaceus), 

and all other indigenous species that recruit through natural means and resemble 

comparable islands in the region that have not been previously affected by rats; 

• <5% introduced niu cover of total vegetated area;

• Free of introduced terrestrial nonnative predators and other nonnative animals; and

• Free of pest and nonnative plants. 

Strategies Applied to Achieve Objective 

Within 2 years, prepare a monitoring and rapid response program for terrestrial nonnative species 

and respond immediately if detected 

Maintain cover of introduced niu at or below 5% using mechanical removal or direct application of 

herbicides as appropriate 

Within 2 years, review existing vegetation community distribution data and develop GIS database 

of terrestrial and marine habitats and update them regularly 

Within 3 years and working with experts, prepare a restoration design that identifies which desired 

species will require active propagation and outplanting and which will recruit naturally now that rat 

herbivory has been eliminated. Part of this strategy will be to work with universities and other 

partners to investigate composition and structure of terrestrial communities on Rose Island prior to 

the introduction of rats to inform ecological restoration activities 

Within 4 years, review available vegetation data and develop and implement a monitoring protocol 

to track changes in numbers, cover, and basal area of different species 

Within 5 years, implement restoration design and begin outplanting vegetation if required 

Within 3 years, develop and implement a monitoring protocol to track seabird abundance, nesting 

rates, and feeding territories. Include remote sensing (e.g., cameras) observations to improve future 

monitoring efforts 

Within 10 years, eradicate the scale insect (Pulvinaria urbicola) and any other nonnative insects, 

specifically focusing on eradicating introduced ant species that facilitate scale growth and spread 

Rationale: The tropical wet littoral forest ecotype has become very rare in the Pacific Islands due to the 

value of mesic coastal sites for human habitation. There are no records of the species composition of the 

forest on Rose Island prior to the introduction of Polynesian rats. When first described, Rose Island had a 

native plant community made up of only pu’a vai, tamole, and ufi’atuli (Mayor 1921, Setchell 1924, 

Satchet 1954) and the introduced niu. Presently, the forest is dominated by tausuni but this is a recent 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Chapter 2. Refuge Management Direction 2-17

change in forest community. Tausuni was not recorded on Rose Island until 1970 (Swerdloff and 

Needham 1970). 

Tausuni is indigenous to the Pacific and provides habitat for tree-nesting seabirds. Since rats were 

eradicated at the Refuge in 1993, the plant community has been released from this source of seed and 

seedling herbivory so propagules that wash ashore are now able to survive, increasing the total number of 

species present to at least eight. Factors leading to the decline of the pu’a vai forest and subsequent 

dominance of tausuni include hurricane damage from six significant storms since 1987, and the 

introduction of the scale insect. In March 2011, there were only three very unhealthy large pu’a vai trees 

remaining on Rose Island but a number of seedlings and saplings survive.

The littoral forest on Rose Island provides nesting habitat for the majority of seabird species in the Refuge 

as well as the Pacific reef heron. Various seabirds nest in different parts of the forest with some nesting in 

the trees and others nesting on the ground. Niu have been planted on Rose Island on several occasions 

(Satchet 1954). While early attempts to establish niu failed (perhaps due to the presence of the rat), there 

is presently a thriving population that is spreading rapidly. If no efforts are made to control the niu, it is 

very possible they will become the dominant vegetation on Rose Island. This would be highly detrimental 

to seabird populations since the straight trunks of nui do not provide places to build nests, and falling 

coconuts can crush birds. While eradication of nui is a possibility, it is desirable to maintain a small nui 

grove due to their importance in Samoan culture. 

Invasive ants, including Pheidole megacephala and Tetramorium bicarinatum, are severely disrupting the 

ecology of the atoll, including facilitating an outbreak of Pulvinaria urbicola, an invasive scale insect 

responsible for killing pu’a vai trees. These aggressive, predatory ants are also likely reducing numbers of 

arthropods native to the atoll. Once ants are removed, natural enemies of the scale, such as predaceous 

beetles and parasitic wasps that may now be prevented from attacking the scale by the ants, may increase 

in number and reduce scale abundances to a level better tolerated by pu’a vai. Pu’a vai trees are declining 

throughout their range, and the eradication of ants will facilitate the removal of Pulvinaria scale and help 

in the recovery of the pu’a vai forest. 

Fua’o nesting in pu’a vai. USFWS
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

2-18 Chapter 2. Refuge Management Direction

2.3.6 Goal 6. Gather scientific information (inventories, monitoring,

assessments, and research) to support adaptive management decisions under 

objectives for Goals 1-5. 

Objective 6.1 Conduct high priority inventory and monitoring (survey) activities and 

scientific assessments. 

Conduct inventory and monitoring activities that evaluate resource management activities to 

facilitate adaptive management. These surveys contribute to the enhancement, protection, 

preservation, and management of wildlife populations and their habitats on and off Refuge lands. 

Specifically, they can be used to determine if we are meeting resource management objectives 

identified under Goals 1-5. These surveys have the following attributes: 

• Data collection techniques will 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;

• Studies will be designed to statistically detect early stages of habitat changes that would 

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; 

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

and applicable; and

• Annual and cumulative reports will be completed for all inventory, monitoring, and research 

activities to document results and provide comprehensive analyses.

Priority inventory and monitoring activities 

Finalize Memorandum of Understanding (MOU) with DMWR to coordinate data collection and 

management activities at the Refuge 

Work with partners to deploy an Ecological Acoustic Recorder (EAR) in the ava to collect 

biological data that may improve monitoring of behavior and abundance of marine organisms 

Within 5 years, begin to monitor climate change variables including sea level, temperature 

(air/water/substrate), water quality (pH, conductivity, dissolved oxygen, nitrogen, 

photosynthetically available light (PAR), phosphorus, iron), the frequency and duration of extreme 

storm events, and biological responses (phenological, developmental, physiological) 

Work with partners to monitor status and trends of focal communities (hard corals, algae), including 

the incidence and severity of coral and algal disease and bleaching

Within 5 years, monitor the growth and survival rate of coral colonies at different depths 

Work with partners to conduct REA to document habitat associations and species distribution, 

density, and diversity in marine habitats 

Work with NOAA’s CRED and other partners to collect oceanographic and water quality data in 

order to track changes that could affect the reef or wildlife 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Chapter 2. Refuge Management Direction 2-19

Priority inventory and monitoring activities (continued)

Within 5 years, develop and implement monitoring protocols to track populations of focal lagoon 

species, including fish, corals, faisua, other invertebrates, and marine pests to determine abundance, 

density, and biomass of each at selected sites 

Work with partners to collect bathymetry data every 10 years in order to document changes in the 

lagoon, reef, or ava which could affect hydrography or habitat characteristics 

Within 5 years, develop and implement monitoring protocols to track abundance and distribution of 

focal perimeter reef species including eels and urchins to determine abundance, density, and 

biomass of each at selected sites 

Continue monitoring abundance and distribution of the cyanobacterial community which became 

dominant on a section of the southwest arm of the atoll following the 1993 shipwreck 

Monitor benthic succession of the reef which was damaged due to the 1993 shipwreck 

Within 5 years, work with partners to expand the reef monitoring program, including rate of growth, 

elevation change, chemical composition, and other variables related to reef growth and the atoll’s 

ability to maintain itself in an anticipated environment of climate change and ocean acidification 

Within 5 years, work with partners to monitor water flow rate and direction in the ava using archival 

pressure and flow rate instruments that can be downloaded at every visit in order to document any 

changes in flow through the ava 

Within 5 years, develop and implement monitoring protocol to track abundance and biomass of fish, 

including predator and prey fish species, around the opening of the ava to detect any changes in 

structure or function of this important geological feature for large predators in the Refuge 

Conduct study to determine if aquifer exists at Rose Atoll. If found, within 5 years begin 

monitoring the lens to document extent and changes 

Within 2 years, working with NOAA/NMFS and other partners, develop and implement monitoring 

protocol to track turtle abundance and movements using field counts, tagging, remote sensing, and 

satellite telemetry 

Within 2 years, use GPS to map the perimeter of the islands at high and low tide on each visit to the 

Refuge and obtain any available satellite imagery for incorporation into GIS in order to document 

changes in island size, shape, and location 

Monitor survivorship, growth, and maturation of outplanted tamole 

Within 2 years, prepare and implement a monitoring plan and rapid response program for terrestrial 

nonnative species and respond immediately if detected 

Within 2 years, review existing vegetation community distribution data and develop GIS database 

of terrestrial and marine habitats and update them regularly 

Within 4 years, review available vegetation data and develop and implement a monitoring protocol 

to track changes in numbers, cover, and basal area of different species 

Within 3 years, develop and implement a monitoring protocol to track seabird abundance, nesting 

rates, and feeding territories. Include remote sensing (e.g., camera) observations to improve future 

monitoring efforts 

Install weather station for long-term monitoring of weather data
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

2-20 Chapter 2. Refuge Management Direction

Rationale: The Administration Act requires us to “monitor the status and trends of fish, wildlife, and 

plants in each refuge.” Surveys will be used to track populations and abiotic variables in order to 

assess progress toward achieving refuge management objectives (under Goals 1-5 in this CCP) 

derived from the Refuge System mission, refuge purposes, and maintenance of BIDEH (601 FW 3). 

Determining resource status and evaluating progress toward achieving objectives is essential to 

implementing adaptive management on DOI lands and waters as required by policy (522 DM 1). 

Specifically, results of surveys will be used to refine management strategies over time in order to 

achieve resource objectives. Surveys will provide the best available scientific information to promote 

a transparent decision-making process for resource management on refuge lands and waters. 

Monitoring data will help us track the effects of climate change and ocean acidification on the 

Refuge. As a living reef, built and maintained by CCA, corals, and other calcifying organisms, Rose 

Atoll will be particularly susceptible to sea level rise and ocean acidification. As the sea rises, the 

reef will need to grow faster to maintain the same elevation in relation to sea level. At the same time, 

the concentration of carbonate ions (needed by calcifying organisms to build the reef) will be 

declining due to ocean acidification. Coral bleaching will also become more common as the ocean 

warms. Monitoring the growth of the reef and abiotic factors will help us understand what is 

happening to the reef and predict and plan for future conditions. 

In accordance with DOI policy for implementing adaptive management on refuge lands (522 DM 1), 

appropriate and applicable environmental assessments are necessary to determine resource status, 

promote learning, and evaluate progress toward achieving objectives whenever using adaptive 

management. These assessments will 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 1-5.

Monitoring Porites lutea at Rose Atoll. 

Jim Maragos/USFWS
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Chapter 2. Refuge Management Direction 2-21

Objective 6.2 Facilitate high priority research at the Refuge to directly support 

management objectives and guide management decisions. 

Facilitate research projects that provide the best science for habitat and wildlife management on and off 

the Refuge. Scientific findings gained through these projects will expand knowledge regarding lifehistory needs of species and species groups as well as identify or refine habitat and wildlife management 

actions. These research projects have the following attributes:

• Focus wildlife population research on assessments of species-habitat relationships. Develop 

models that predict wildlife response to management;

• Design and conduct issue-driven (problem-driven) research unlikely to be reliably addressed 

using long-term monitoring; 

• Promote Refuge research and science priorities within the broader scientific community. Ensure 

that cooperative research focuses on meeting information needs identified in biological goals 

and objectives; 

• Assign a high priority to the collection of information that will help managers predict, 

understand, and address the effects of climate change and ocean acidification on fish, wildlife, 

and their habitats at all spatial scales in the Refuge;

• Data collection techniques will 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;

• Annual and cumulative reports will be completed for all inventory, monitoring, and research 

activities to document results and provide comprehensive analyses.

• Follow quarantine and cleaning protocols to avoid or minimize the potential spread or 

introduction of nonnative and pest species; and 

• Often result in peer-reviewed articles in scientific journals or symposium publications. 

Priority research needed

Characterize nutrient budgets and dynamics at Rose Atoll and evaluate them relative to data from other 

similar reef sites to identify possible stressors and the positive effects of healthy seabird colonies 

adjacent to living reefs 

Evaluate the geomorphology, hydrology, and sediment budget of Rose Atoll to understand the processes 

that have maintained the islands as dynamic units 

Investigate the ecological relationships between marine gastropods such as turban shells (Turbo spp.) 

and land hermit crabs (Coenobita perlatus and C. brevimanus). Evaluate factors affecting crab 

populations, including observed reduction in availability of shells to crabs at the Refuge and what 

management may improve mollusk shell availability to the Coenobita spp., which are important 

scavengers and herbivores on both islands 

Investigate composition and structure of terrestrial communities on Rose Island prior to the introduction 

of rats to inform ecological restoration activities 

Investigate food habits of seabirds breeding at Rose Atoll using stable isotopes and stomach samples 

Correlate reproductive performance indicators and breeding chronology variation in Rose seabird 

populations with oceanographic conditions and location of migratory fish schools relative to the atoll
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

2-22 Chapter 2. Refuge Management Direction

Rationale: Rose Atoll is unique in the Samoan Archipelago in being a coralline algal atoll. Research 

projects on Refuge lands and waters will address a wide range of natural resource questions. 

Examples of research projects include habitat use and life-history requirements for particular species, 

practical methods for habitat management and restoration, extent and severity of environmental 

contaminants, techniques to control or eradicate pest species, effects 

of climate change, and ocean acidification on environmental 

conditions and associated habitat and wildlife response, 

identification and analyses of paleontological specimens, wilderness 

character, and modeling of wildlife populations. Projects may be 

species-specific, Refuge-specific, or evaluate the relative 

contribution of the Refuge to larger landscape (e.g., archipelago, 

regional, Pacific, global) issues and trends. 

As with monitoring, results of research projects will expand the best 

available scientific information and potentially reduce uncertainties 

to promote transparent decision-making processes for resource 

management over time on the Refuge and other protected areas. In 

combination with results of surveys, research will promote adaptive 

management on the Refuge. Scientific publications resulting from 

research on the Refuge will help increase the understanding of the 

Refuge System for resource conservation and management in the 

larger science realm.

2.3.7 Goal 7. Strengthen resource conservation and the public’s shared 

stewardship of the ecological, geologic, and cultural richness of the Refuge by 

providing outreach, interpretation, and environmental education 

opportunities. 

Objective 7.1 Enhance and expand interpretation and outreach.

Provide high quality interpretation and outreach that supports a knowledgeable public who are 

aware of the conservation provided by the Refuge. The public is informed about the Refuge’s 

complex ecosystem, cultural connections, geologic history, and management challenges by focusing 

on “bringing the Refuge to the people, instead of the people to the Refuge.” Interpretation and 

outreach associated with the Refuge will have the following attributes:

• People are exposed to at least one of the four key interpretive themes regarding Ecology; 

Geology; Samoan Culture; and/or the NWRS; 

• Products and messages engage a diverse audience from American Samoa and across the 

United States and Oceania;

• Outreach and interpretation use standard media as well as social media and evolving 

technologies; and

• Supports the Service’s “Connecting People with Nature” emphasis.

Pu’a vai research. USFWS
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Chapter 2. Refuge Management Direction 2-23

Strategies Applied to Achieve Objective 

Install minimal signage on Rose Island to inform people of Refuge boundary and regulations 

Maintain Refuge website and update at least annually with current information such as species lists, 

interactive tools, management updates, news releases, science reports, etc. 

Develop brochures, Website, and utilize social media and other outreach tools specifically designed 

to communicate Refuge protection and safety issues and make these available to mariners 

Develop outreach messages using social media such as blogs or interpretive videos online to “bring 

the Refuge to the people” 

Develop virtual fieldtrip to Rose Atoll with link on Website by 2016 

Explore opportunities and community interest for supporting the development of a Refuge 

“Friends” group to help with interpretation, outreach, and other Refuge needs 

Develop a Refuge volunteer program to provide local and national stewardship opportunities and 

assist in Refuge management activities

Work with partners (especially within the Manu’a Islands) to develop multi-lingual interpretive 

displays and print materials to provide outreach messages at visitor centers as well as mobile 

displays for traveling exhibits 

Participate in community meetings and local events to educate people about the Refuge, especially 

within the Manu’a Islands 

Enhance law enforcement through the production of interpretive brochures for distribution in 

American Samoa and to the yachting community 

Collaborate with the USCG and NOAA for law enforcement 

Work with partners to deploy an EAR in the ava to collect data on boat entry into the lagoon 

Rationale: The fundamental purpose of Service outreach is to build understanding, trust, and support 

from a variety of groups by helping them understand what the Service does and why we do it. 

Because the Refuge is closed to the general public, our interpretation and outreach program will be 

based on “bringing the Refuge to the people,” instead of bringing the people to the Refuge. We will 

work with our partners to establish Refuge displays for visitor centers in American Samoa, and 

develop outreach materials and social media capacity to provide other interpretive opportunities for 

people in American Samoa and around the world. Virtual field trips are alternatives to more costly 

real-world field trips. In addition to being inexpensive in consideration with the number of students 

who can be reached, they are engaging to students because they enable students to make connections 

between themselves and wide-ranging environments they can explore on-line. 

The Service did not have staff stationed in American Samoa prior to 2011, so outreach messages 

describing how Rose Atoll NWR fits in the Refuge System need to be developed for the local 

communities. Good communication with elected officials is essential for the Service to be effective 

and responsive to the American Samoa public. Conservation groups have a great interest in resource 

management, and their support can influence others. Businesses can be a source of funding or 

support through partnerships. Other Federal agencies, as well as American Samoa and village 

governments, can help give momentum to the Service’s outreach initiatives, and their support can 

enhance a project’s likelihood of success. 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

2-24 Chapter 2. Refuge Management Direction

Objective 7.2 Develop environmental education products and programs to perpetuate 

and enhance knowledge and appreciation of wildlife, habitats, and their importance to 

American Samoa culture and the world. 

Provide a high quality Rose Atoll EE program with the following attributes: 

• Focuses on students in American Samoa from pre-K through college; 

• Aligns with the American Samoa Department Of Education Learning Management System; 

• Involves local teachers to ensure program is relevant to local students and curricula; 

• Incorporates measurable learning objectives and uses audience-appropriate curricula; and 

• Supports and complements the Service’s mission, and the Refuge’s purposes and goals. 

Strategies Applied to Achieve Objective 

Create Rose Atoll EE materials such as DVDs and posters for use with school groups 

Work with partners to develop EE curricula and classroom materials that introduce students to 

American Samoa wildlife, protected areas, and conservation of natural resources, especially in 

relation to effects from man-made climate change

Partner with schools and universities to conduct surveys and/or relevant research 

Explore appropriate on-site EE opportunities (<once every 3 years) to allow a small group of 

teachers and students (<10 people) to visit the Refuge for specific EE purposes developed with the 

Refuge’s EE program 

Develop a brief, picture-oriented presentation describing the ecology of the Refuge and present this 

to three American Samoa schools each year 

Develop a student intern program with the Refuge office to introduce students to protected areas 

and wildlife management

Rationale: American Samoa is a rapidly changing society which is in the process of enhancing EE in 

the schools’ curriculum. This creates an excellent opportunity for the Service to play a role in helping 

to develop EE programs. As a small Refuge with a small staff, working with our partners will be vital 

to the success of any EE program. Because we manage a coral and crustose coralline algal atoll in 

American Samoa, the Service is in a position to educate people about the effects of climate change 

and ocean acidification.

In the past, the Service has had a very limited EE program. There have been rare trips to the Refuge 

for teachers and students, but these trips are very expensive, can only be done with strict biological 

restrictions in place to avoid disturbance, and only reach a handful of students. We will be able to 

reach many more students offsite through outdoor programs, classroom presentations and activities, 

and internship programs. We can include people outside of American Samoa with an improved 

presence on the Internet and the development of classroom materials for downloading. 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Chapter 2. Refuge Management Direction 2-25

2.3.8 Goal 8. Identify, protect, preserve, and interpret the Refuge’s Samoan 

cultural resources and facilitate, where appropriate, cultural practices.

Objective 8.1 Encourage and facilitate identification, protection, and perpetuation of 

Samoan cultural resources, practices, and traditions related to Rose Atoll. 

Increase identification, monitoring, and protection of cultural resources, while increasing staff and 

public support and appreciation. These efforts will focus on accomplishing the following: 

• Expand knowledge of the Samoan cultural resources related to Refuge; and 

• Facilitate Refuge-appropriate cultural practices. 

Strategies Applied to Achieve Objective

Research the history of Samoan names for Rose Atoll and consider changing Refuge name 

accordingly

Work with the American Samoa Historical Preservation Office to conduct an archaeological survey 

at Rose Atoll

Consult with the OSA and local villagers to understand and perpetuate Refuge-appropriate 

traditional cultural practices related to Rose Atoll

Work with partners to collect and compile oral histories from village leaders 

Work with partners to create bilingual education materials such as videos, reports, and pamphlets 

regarding cultural uses and the oral history of Rose Atoll 

Restore the cement monument erected on Rose Island during the Governor’s 1920 visit 

Rationale: During public meetings held in 2009, people expressed the desire that the oral history and 

cultural resources and traditions of Rose Atoll be preserved. There was also the desire that the 

Samoan people be allowed some access to the Refuge for cultural practices. The Service recognizes 

that observing and perpetuating cultural practices and resources is an essential part of 3000 years of a 

unique Samoan heritage and we will work closely with the OSA and villages to protect these 

resources and manage the Refuge consistent with fa’asamoa (the Samoan way).
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

2-26 Chapter 2. Refuge Management Direction
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 3. Physical Environment 3-1 

Chapter 3. Physical Environment

3.1 Climate 

The climate of Rose Atoll can be generalized as tropical, with moderate breezes and moderate 

rainfall. Because Rose Atoll is a small atoll with two tiny islands only a few feet above sea level, the 

climate there is similar to the open ocean. The ocean temperature in American Samoa averages near 

82 ̊F and may vary by 2–3 degrees seasonally. Since both islands are at 14 degrees south latitude, 

temperature data are comparable between the islands. The constant ocean temperature has a strong 

moderating effect on the climate. Data must be generalized from Tutuila Island 180 miles away 

because there is not a climate monitoring station at Rose Atoll. 

While the climate of American Samoa is warm and wet year-round, there is some seasonal 

variability. The wetter, warmer season is October–May and the cooler, drier season is June–

September. In the warm season air temperature averages 83 ̊F, and rainfall averages about 13 inches 

a month at the airport in Tutuila. In the cool season, air temperature averages around 81 ̊F, and 

rainfall averages about 6 inches a month. Due to a lack of any real topography, Rose Atoll receives 

substantially less rain than Tutuila, but the precipitation is enough to support the littoral forest 

(Wegmann and Holzwarth 2006). 

Aside from being the drier and cooler season, June–September is also the trade wind season with 

winds blowing out of the southeast. Hurricanes are more common November–April when the ocean 

is slightly warmer (Craig 2009). There have been six hurricanes in Samoa between 1980–2011, some 

of which have caused forest and reef damage at Rose Atoll. 

3.1.1 Climate Change

Climate change can be defined as a change in the state of the climate characterized by changes in the 

mean or the variability of its properties, persisting for an extended period, typically decades or longer 

(IPCC 2007). Climate variables that may change include temperature, water vapor, sea level, 

Placid lagoon. Greg Sanders/USFWS
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

3-2 Chapter 3. Physical Environment

precipitation, etc. Such changes are part of the natural system, but can also be affected by human 

activities, particularly in the form of emissions of greenhouse gases (GHG) such as carbon dioxide 

(CO2). The Intergovernmental Panel on Climate Change (IPCC) is a scientific intergovernmental 

body organized by the World Meteorological Organization and the United Nations Environment 

Programme 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 (IPCC 2007). 

Global climate models offer a variety of projections based on different emission scenarios. The U.S. 

Global Change Research Program suggests that a continuing increase in GHG emissions (CO2, 

methane, and nitrous oxides of primary concern) could double atmospheric concentrations of CO2 by 

2060 and subsequently increase temperatures by as much as 2–6.5°F over the next century. Sea level 

rise (SLR) is expected to accelerate by 2–5 times the current rate due to both ocean thermal 

expansion and the melting of glaciers and polar ice caps. Recent modeling projects sea level rising by 

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, IPCC 2007). 

3.1.2 Climate Change at Rose Atoll. 

Small island groups are particularly vulnerable to 

climate change. The following characteristics 

contribute to this vulnerability: small emergent land 

area compared to the large expanses of surrounding 

ocean; limited natural resources; high susceptibility to 

natural disasters; and inadequate funds to mitigate 

impacts (IPCC 2001). Thus, Rose Atoll is considered 

to have a limited capacity to adapt to future climate 

changes. Other stressors brought on by increased CO2

will be increasing at the same time, and some of them 

may work synergistically (Anlauf et al. 2010, Hoeke 

et al. 2011). Sea-level rise, higher ocean 

temperatures, ocean acidification, and a likely 

increase in hurricane strength will all affect the reef 

and organisms of Rose Atoll and some factors will 

intensify others. 

 

Sea Level Rise. According to the IPCC, the oceans 

are now absorbing more than 80% 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 occurred 18-foot storm surge effects on Rose Island. 

Holly Freifeld/USFWS
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 3. Physical Environment 3-3 

historically 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 rose about 6 inches and this is 

likely to rapidly increase in the next century (Noye and Grzechnik 2001, GAO 2007). 

Near Pacific Island ecosystems, SLR is influenced by the rate and extent of global SLR, as well as 

changes in episodic events, such as the El Niño Southern Oscillation (ENSO, which results in light 

trade winds in the western Pacific and drier conditions) and the varying strength of trade winds over 

multi-year timespans. 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). 

Despite this variability, SLR will have an impact on Rose Atoll, specifically to the reef height that 

currently protects the islands and lagoon habitats. The rate of growth of corals and CCA (i.e., 

calcification) must meet or exceed the rate of erosion and SLR to maintain current conditions. 

Biological accretion of the reef will also be affected by increased temperatures, changes in seawater 

chemistry, and increases in destructive weather events. For Samoa, monthly averages of the historical 

tide gauge, satellite (since 1993), and gridded sea-level (since 1950) data agree well after 1993 and 

indicate interannual variability in sea levels of about 7.9 inches (estimated 5–95% range) after 

removal of the seasonal cycle. The SLR near Samoa measured by satellite altimeters since 1993 is 

about 0.16 inches per year, slightly larger than the global average of 0.13 ± 0.016 inches per year. 

This rise is partly linked to a pattern related to climate variability from year to year and decade to 

decade (PCCSP 2011). Increased water depths on reef flats may allow for faster upward growth of 

the reef flat (Brown et al. 2011) but other factors such as ocean acidification may be slowing reef 

growth at the same time. It is not yet clear whether reefs will continue to produce enough sand to add 

to both islands to maintain them above sea level. 

Ocean Temperatures. Many corals are living near the limit of their thermal tolerance, and 

increasing sea-surface temperatures are leading to more frequent cases of coral bleaching. Coral 

bleaching is a condition where corals expel the tiny zooxanthellae (microscopic plants) that live 

inside the coral tissues and provide food for the coral through photosynthesis. The zooxanthellae give 

coral their colors. When corals expel their zooxanthellae in high temperature conditions, the coral 

appears bleached white because we see through the translucent live coral tissue to the skeleton. If 

temperatures rise just slightly above the bleaching threshold, corals can recover, but higher 

temperatures typically cause coral mortality. The longer the corals are exposed to higher 

temperatures, the less likely they are to recover. With warming oceans, corals will suffer more 

frequent, more severe, and longer duration bleaching events. More frequent and severe coral die offs 

are expected to cause coral populations to decline because they will have less time to recover 

between these stress events and while under this stress, their reproductive capacity is diminished 

(Hoeke et al. 2011, Buddemeier et al. 2004, Hoegh-Guldberg et al. 2007). 

 

Different corals have different tolerances to sea-surface temperature (Fabricius et al. 2011), so 

bleaching will likely lead to changes in the coral communities. American Samoa is already 

experiencing this with mass bleaching events in 1994, 2002, and 2003 (Craig 2009) and annual 

summer bleaching in back reef pools of Tutuila (Fenner and Heron 2009). By mid-century, coral 

reefs are predicted to be shifting rapidly from coral-dominated to algae-dominated (Hoeke et al. 

2011, Buddemeier et al. 2004, Hoegh-Guldberg et al. 2007). 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

3-4 Chapter 3. Physical Environment

Storm Frequency and Intensity. Most climate 

projections suggest that more intense wind speeds 

and precipitation amounts will accompany tropical 

hurricanes and increased tropical sea surface 

temperatures in the next 50 years. The intensity of 

tropical hurricanes is likely to increase by 10–20% in 

the Pacific region when atmospheric levels of CO2

reach double preindustrial levels (McCarthy et al. 

2001). One model projects a doubling of the 

frequency of 4 inches per day rainfall events and a 

15–18% increase in rainfall intensity over large areas 

of the Pacific. While powerful storms can move 

through deep ocean without leaving much evidence, 

these hurricanes have the ability to cause great 

damage to terrestrial species on islands – as seen in 

2005 when Hurricane Olaf, a Category 5 storm, hit 

Rose Atoll and washed over much of Rose and all of 

Sand Islands causing loss of forest cover and 

mortality of seabird eggs and chicks. 

Shallow reef organisms are also affected by being 

buried by redistributed sediment. Coral reefs are also 

damaged by hurricanes when wave height and 

energy break apart coral reefs. Storms toss chunks of 

the fore reef up onto the reef platform, leaving 

Rose’s characteristic boulder-strewn reef flat. 

During the past 30 years, hurricanes have impacted 

American Samoa at intervals of 1–13 years: 1981 

(Esau), 1987 (Tusi), 1990 (Ofa), 1991 (Val), 2004 

(Heta) and 2005 (Olaf), and 2010 (Wilma). 

Ocean Acidification. In addition to SLR and warmer ocean temperatures, as CO2 levels rise, corals 

and coralline algae will live in an ocean that is more acidic and contains less carbonate. Corals and 

CCA need a minimum concentration of carbonate ion (CO2) in sea water to build their calcium 

carbonate skeletons. As CO2 increases in the ocean it triggers a series of reactions that remove CO2

from the water. Thus, the same process that makes the ocean more acidic, reduces the concentration 

of CO2. Reef building requires a minimum carbonate concentration of 200 micromoles per kilogram, 

and concentrations are presently at 210 micromoles per kilogram and dropping (Hoegh-Guldberg et 

al. 2007). Once atmospheric CO2 reaches 550 parts per million, scientists predict calcification of 

corals will stop in the Samoa area (Jokiel et al. 2008, Guinotte et al. 2003). Early research shows that 

CCA are even more susceptible to reductions in carbonate than corals (Kuffner et al. 2008). Coralline 

algae form the rose-colored reef crest that protects the reef flat and islands from erosion. Once 

acidification slows or stops that growth, the reef flats and islands will be at risk. While research still 

needs to be done, the long-term outlook for Rose Atoll and other coral reefs is one of slowed growth 

due to decreased calcification and increased erosion. 

Additional 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 

Rose Island before Olaf (top) and Rose Island after Olaf 

(below), where ocean inundation is clearly visible. USFWS
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 3. Physical Environment 3-5 

ecosystem structure and dynamics. For example, paleoecological studies have shown that the 

distribution of vegetation is highly influenced by climate. The reproductive physiology and 

population dynamics of amphibians and reptiles are highly influenced by environmental conditions 

such as temperature and humidity (i.e., sea turtle gender 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 (Duffy 1993, Walther et al. 2002, Baker et al. 2006) by increasing thermoregulatory stress in 

young chicks. 

Warming has also caused species to shift toward the poles or higher altitudes and changes in climatic 

conditions can alter community composition. Increases in CO2 levels can affect plant photosynthetic 

rates, reduce water stress, decrease nutrient content, and lower herbivore weights. Climate change 

can also increase the loss of species as has been shown by the extirpation of two populations of the 

Bay checkerspot butterfly (Euphydryas editha bayensis) in California (Bedoya et al. 2008). Some of 

the characteristics that make species vulnerable include small population sizes, restricted or patchy 

ranges (such as those organisms that live on isolated islands), occurrences at either high or low-lying 

areas, with limited climatic ranges, and narrow or specific habitat requirements. 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). 

Effects of climate change to nesting i’a sa on Rose Island could include loss or degradation of nesting 

habitat from sand erosion, and changes in incubation times, hatchling success, and sex ratios. As 

incubation temperature increases, incubation time goes down, the sex ratio is predicted to be highly 

biased toward females, and hatchling survival will be reduced (Fuentes et al. 2011). 

Effects of climate change to seabirds could include loss/degradation of nesting habitat from sand 

erosion and changes in food source abundance or behavior because of changes in the pelagic 

ecosystem. Increased salt water intrusion onto Rose Island may lead to the loss of vegetation that is

less tolerant of salt water, while increased erosion would lead to the loss of terrestrial habitats. 

Climate change represents a growing concern for the management of national wildlife refuges. The 

Service’s climate change strategy, titled “Rising to the Urgent Challenge,” establishes a basic 

framework for the agency to work within a larger conservation community to help ensure wildlife, 

plant, and habitat sustainability (USFWS 2010). In addition, the Service is supporting regional 

Landscape Conservation Cooperatives (LCC). These cooperatives are public-private partnerships that 

recognize conservation challenges transcend political and jurisdictional boundaries and require a 

more networked approach to conservation—holistic, collaborative, adaptive, and grounded in science 

to ensure the sustainability of America’s land, water, wildlife and cultural resources. 

The local LCC is the Pacific Islands Climate Change Cooperative (PICCC), headquartered in 

Honolulu, Hawai‘i, and 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 

nongovernmental conservation organizations and academic institutions, forming a cooperative 

partnership that determines the overall organizational vision, mission, and goals. 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

3-6 Chapter 3. Physical Environment

Depths at Rose Atoll. USFWS

3.2 Hydrology

No known hydrological studies have been conducted at Rose Atoll. There are no streams, lakes, 

wetlands, or any other surface water on Rose Atoll (Brainard et al. 2008). Rain water on Rose Island 

is likely taken up by plant roots and lost through transpiration. It is unlikely that any freshwater is 

stored in the sediments of Rose Island in a lens above sea level because of the small size of the 

islands. However, no aquifer studies have been conducted at either Rose or Sand Islands. 

3.3 Topography and Bathymetry

Both islands have elevations of less than 15 feet and are subject to wash overs by waves in larger 

storms. Because both islands have components of mobile sand and coral rubble, they can vary in size 

and shape (Mayor 1921, Satchet 1954, Setchell 1924, Shallenberger et al. 1980, Williamson 1998), 

but maintain their position on the reef due to central cores of rock. Freycinet pointed out in 1826 that 

Rose Island was highest in the southwest and gradually sloped down toward the northeast where it 

merged with the sand of the shore (Rodgers et al. 1993). Rose Island has the same basic shape today. 

Sand Island is more variable in shape because it is not a pinned island. Mostly likely, Sand Island 

maintains the same basic size and location over the years because of its location in the eddy of the 

ava. 

Below the elevation of the islands is the reef crest which maintains roughly the same elevation all the 

way around the atoll. The one exception is the ava, the channel that connects the lagoon with the 

outside ocean, which is between 6 and 50 feet deep. Inside the reef crest is the lagoon slope, which is 

mostly less than 10 feet deep. In the middle of the atoll is the lagoon with a maximum depth near 98 

feet. On the outside of the reef crest the atoll plummets steeply to the bottom of the Pacific Ocean 

over 2 miles below the surface. In 2006 the NOAA CRED mapped the bathymetry in and around 

Rose Atoll using multibeam equipment and towed-diver surveys. 

 

Image showing the steep sides of Rose Atoll 

sloping rapidly down to more than 2 miles deep. 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 3. Physical Environment 3-7 

3.4 Geology and Geomorphology

The Samoan Island chain is a series of volcanic islands that are sinking back into the Pacific Ocean 

over millions of years. These islands are on the Pacific tectonic plate and surrounded by ocean which 

is mostly 2–3 miles deep. The Pacific plate is moving northwest averaging about 2–3 inches a year. 

About 100 miles south of the Samoan chain, part of the Pacific Plate sinks into the 6-mile-deep 

Tongan Trench and ultimately under the Australian Plate. As the plate moves, it bends and cracks 

creating volcanic hot spots where lava oozes out forming volcanoes and ultimately islands (Birkeland 

et al. 2008). 

Most of the Samoan Island chain was created by a volcanic hot spot, presently located between Rose 

Atoll and Ta’ū under Vailulu’u seamount. The peak of this seamount is about 1,800 feet deep. 

Savai’i is the westernmost island and the oldest with an estimated age around 5 million years. Ta’ū is 

the easternmost island and the youngest with an estimated age around 1 million years. There are 

seamounts west of Savai’i, some of which were likely islands that have sunk below the sea surface. 

Rose Atoll is an anomaly in the Samoan Island chain. It is older than any of the other islands, but lies 

at the younger end of the chain. This is because Rose Atoll was not created by the same hot spot that 

created the rest of the Samoan Islands. It was created by volcanic activity that took place before the 

present hot spot became active (Birkeland et al. 2008). 

Rose started as an ancient volcano that built up from eruptions beginning on the deep sea floor many 

millions of years ago. The ancient volcano emerged as a volcanic island that eventually went extinct, 

leading to its subsidence due to the growing of the volcano pushing down on the ocean floor beneath 

it and natural erosion. The first corals and other reef-building organisms settled on the fringes of the 

volcano and continued to survive, grow, and die, leaving their skeletons behind and allowing younger 

reef builders to settle upon them and grow. This maintained proximity to the sea surface during the 

long period of subsidence. Over millions of years the upward growth rate of the reef kept pace with 

the downward rate of subsidence of the volcano, leading to the creation of a coral cap encircling and 

These photos illustrate how variable island size can be given the dynamic nature of the environment. USFWS
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

3-8 Chapter 3. Physical Environment

eventually covering the summit of the extinct volcano. Eventually the volcano disappeared altogether 

beneath the sea surface and was replaced by a lagoon, completing the transition from volcanic island 

with reefs fringing its coasts to an atoll. 

Darwin’s idea that atolls were perched atop sinking volcanos was verified when scientists drilled 

through more than 4,000 feet of calcium carbonate reef to hit basalt from an ancient volcano. 

However, today we know that the creation of atolls is a more complex process, which has happened 

over the last several thousands of years, not over the millions of years that it takes a volcano to sink. 

The creation of atolls as we know them today, a ringed reef surrounding a lagoon often with sand 

islets, is the result of changes in sea levels that have occurred during glacial and interglacial times. 

During the last glacial period about 20,000 years ago, sea level was over 100 meters (328.1 feet) 

lower than it is today. 

Reefs that had grown 

during times of higher 

sea level protruded out 

of the sea and were 

subject to thousands of 

years of erosion and 

subsidence. 

As the sea rose again, 

these eroded reefs began 

to grow again, but now 

their centers had been 

eroded. Five thousand 

years ago, sea levels 

were about 6.6 feet 

higher than today, so 

these reefs grew higher 

than present day sea 

level. As sea levels have 

gone down, a few yards 

of reef have been 

exposed, and islands 

Samoan Island Chain. National Park of American Samoa

Figure 3-1. Atoll formation.

Source: Woodroffe 2007
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 3. Physical Environment 3-9 

have formed on some of these newly exposed reefs (Dickinson 2009, Woodroffe 2007). 

For most of the last 100,000 years Rose Atoll has been out of the sea. The islands we see at the atoll

today have likely only existed for a few thousand years. The distinctive square shape of the reef 

structure today is thought to reflect the shape of the ancient volcano that had dikes of more resistant 

rock intersecting at a right angle. Although there is insufficient evidence to determine the thickness 

of the coral reef cap at Rose Atoll, coral drilling on Enewetak Atoll in the Marshall Islands has 

revealed a coral reef cap attaining a thickness of over 4,000 feet in depth that began its growth more 

than 50 million years ago (Maragos 2011a). 

Rose has a higher percentage of CCA than most atolls, and this gives Rose a pink hue (Brainard et al. 

2008, Green et al. 1997, Mayor 1921). Aside from the main ring of the atoll, there is a series of 

blocks and pinnacles created by coral and CCA that provide habitat diversity in the lagoon and on the 

back reef. Rose Atoll is one of about 500 surviving atolls in the Pacific today, but countless others 

have drowned well below the lighted (photic) zone of the ocean because their upward reef growth 

could not keep pace with the corresponding downward subsidence and sea level fluctuations during 

the Pleistocene. 

3.5 Soils

The soils on Sand Island and the unvegetated parts of Rose Island are composed of limestone sands 

and rubble of algal and coral origin surrounding and partially covering a core of paleoreef rock. This 

soil is considered to be a Fusi soil type (Amerson et al. 1982). These soils are non-consolidated sands 

that are often washed over during storm events. The sands shift around the rock island core with the 

wave and wind action making the shape and size of the islands dynamic. This is evident in the 

constant necessity to replace grid markers used for biological surveys during visits by Service 

personnel between 1980 and the present. Due to the large numbers of seabirds nesting on the islands, 

there is a substantial input of guano. All the seabirds at Rose forage over deep ocean thus there is a 

constant input of nutrients from outside the atoll system.

The description of the soil that follows is based on a 1924 survey under the Pisonia forest (Lipman 

and Shelley 1924). Changes have taken place as the Pisonia trees have died back and been replaced 

by Tournefortia argentea. The soils in the Pisonia forest can be divided into a top organic layer of 

rich chocolate-colored humus, an intermediate layer of very porous, partially decomposed limestone, 

and a bedrock layer of compact, fine-textured, pure calcium carbonate without texture and no vital 

structure (also described as coquina). Lipman and Shelley (1924) also found high concentrations of 

salt and postulated that the toxic effects of the salts might be mitigated to some degree by the high 

content of organic matter. The soils analysis (from bedrock to soil) also indicated increasingly high 

percentages of aluminum, phosphorus, sulfur, sodium, and potassium, compared to decreasing 

percentages of calcium and magnesium, and little change in silicon. The increased sodium, 

potassium, and sulfur resulted from the large absorptive capacity of the soil, differential leaching, and 

contribution from ocean spray. Nitrate and nitrate producing bacteria were also present in the soils. 

Based on comparison to soils from Pisonia forests in the Marshall Islands, it was suggested that bird 

guano was acidified by humus as it washed down through the soil, leading to a lack of hardpan below 

the humus layer. Lipman and Shelley linked the fertility of Rose Island to the phosphatization, 

followed by bacterial nitrogen-fixation. 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

3-10 Chapter 3. Physical Environment

3.6 Environmental Contaminants 

The Agency for Toxic Substance and Disease Registry (ATSDR), a Federal bureau of the U.S. 

Department of Health and Human Services, defines a contaminant as “a substance that is either 

present in an environment where it does not belong or is present at levels that might cause harmful 

(adverse) health effects” (ATSDR 2009). Contaminants commonly include pesticides and their 

residues, industrial chemicals, fertilizers, metals, and other toxic substances. By altering biological or 

physical processes, contaminants may produce detrimental effects to an ecosystem. 

3.6.1 Military Use in WWII 

On February 14, 1941, the territorial waters surrounding the islands of Rose Atoll were established 

and reserved as the Rose Island Naval Defensive Sea Area. These airspaces over the territorial waters 

and islands were set apart and reserved as the Rose Island Naval Airspace Reservation (Executive 

Order 8683). In 1943 the 4th Marine Base Defense Wing was given permission to use Rose Atoll as a 

dive bomb practice area. In 1996 the Army Corps of Engineers completed a Defense Environmental 

Restoration Project for Formerly Used Defense Sites (FUDS) for Rose Atoll (USACE 1996). In the 

Army FUDS investigation, the only reported ordnance was a single MK–23 practice bomb and two 

0.30-caliber cartridge casings found by biologists. They found no paperwork indicating that Rose 

was ever used for bomb practice. It is also believed that it was not used for storage of fuel or other 

hazardous materials. The FUDS report states, “No land-based evidence of OEW (Ordnance or 

Exploded Wastes) or other military remnants were observed during visual reconnaissance of Rose 

Atoll .... The site was otherwise unremarkable with no signs of Ordnance and Explosive Waste 

(OEW) or environmental stress attributable to former military use” (USACE 1996). 

3.6.2 Wreck of the Jin Shiang Fa 1993

On October 14, 1993, the Taiwanese long-line fishing vessel Jin Shiang Fa ran aground on the 

southwest arm of Rose Atoll spilling 100,000 gallons of diesel fuel, 500 gallons of lube oil, and 

2,500 pounds of ammonia. The vessel broke up before a salvage tug could reach the atoll, depositing 

200 tons of iron on the reef as well as miles of fishing line and other materials from the ship (Green 

et al. 1997). 

The contaminants spilled over a 6-week period were 

washed over the reef and into the lagoon by waves 

and currents. Traces of fuel and oil were detected in 

sediments 22 months later (USFWS and DMWR 

2001). The spill killed the coral and CCA, which 

created openings on the reef for opportunistic 

cyanobacteria and turf algae to colonize. Ultimately 

this led to a phase shift from a CCA-dominated reef 

community to a cyanobacteria/turf algae-dominated 

reef community (USFWS and DMWR 2001). Early 

observations at Rose Atoll also suggested that fish populations may have been affected and large 

numbers of faisua and tuitui died (Green et al. 1997). The iron scattered about the reef from the 

wreck has promoted the continued prevalence of cyanobacteria and turf algae in the reef flat 

community. 

Jin Shiang Fa. USFWS
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 3. Physical Environment 3-11

Though iron removal from the shipwreck was completed in 2007, monitoring of the site continues. 

The natural resource damage assessment, restoration, and monitoring being done by the Service was 

funded by the Oil Spill Liability Trust Fund, established by the Oil Pollution Act of 1990 and 

managed by the U.S. Coast Guard National Pollution Funds Center. 

3.7 Air Quality

Being over 2,700 miles to Sydney, Australia, 4,700 to Los Angeles, California, and 6,000 miles to 

Peru, Rose Atoll is a long way from any major source of air pollution. No known air quality 

sampling has taken place, however, due to the lack of human presence and on-site vehicles (other 

than boats used for Refuge management 1–2 times a year), distance to air polluted areas, and trade 

winds, air quality is thought not to be impaired. 

3.8 Water Quality

Though little water quality monitoring has been done at the Refuge, given its remote location, it is 

anticipated that ocean water quality is not impaired. Water quality testing was conducted after the Jin 

Shiang Fa ran aground on the atoll in 1993, spilling 100,000 gallons of diesel fuel and other 

contaminants into the waters in and around Rose Atoll. Shortly after the grounding, the majority of 

the vessel hull was removed from the reef. Despite the removal of much of the metallic debris from 

the fore reef slope, there was a sufficient source of dissolved iron seaward of the reef edge to sustain 

Disarticulated engine block and scrap metal on coral. USFWS

Debris clean up. Jim Maragos/USFWS 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

3-12 Chapter 3. Physical Environment

Cyanobacteria overgrows pink crustose coralline algae. 

Jean Kenyon/USFWS

elevated iron levels in the water flowing over the reef platform. In 2002, concentrations of iron were 

still elevated 5–10 fold above background levels (approximately 0.6 nanomoles) within a plume of 

water approximately 557 yards wide flowing onto the reef platform. However, peak concentrations 

within the plume in 2002 were only half of the peak values found in 1998. 

Iron is a limiting element in atoll marine 

environments that are far from continental margins, 

and this increased iron resulted in higher 

cyanobacterial growth near the wreck site (Green et 

al. 1997). There have been several cleanup 

operations funded to remove the remaining pieces of 

the ship, and by 2007 all major pieces had been 

removed. Measurements of iron concentration in the 

water upstream and downstream of the wreck site 

continue as part of the monitoring program 

evaluating recovery from the Jin Shiang Fa

grounding. Monitoring is ongoing and new 

strategies for active restoration of the area are being 

evaluated.

Storm wash over and sand erosion on the two islands may periodically lead to temporary turbidity in 

near shore waters. Storm wash and rainfall could also lead to nutrient enrichment from bird guano in 

the marine environment. The nutrient budgets of coral reef systems adjacent to healthy seabird 

colonies and areas where seabird populations have been extirpated is currently an area of active 

investigation in tropical regions around the world. 

3.9 Surrounding Land and Water Use 

In 2009, Presidential Proclamation 8337 created the Monument which overlays the Refuge and 

extends out 50 nmi covering a total of 13,451 square miles. There is no commercial fishing allowed 

in the Monument, and large vessels (greater than 50 feet) are excluded from fishing in an area 

roughly 50 nmi from all the islands and atolls of American Samoa per NMFS regulations (Federal 

Register 2012). The Refuge and the Monument are in the American Samoa Exclusive Economic 

Zone. 

Commercial fishing is prohibited in the Monument, and all fishing is prohibited within 12 nmi of the 

Refuge. Non-commercial fishing is allowed in the Monument outside of the 12 nmi no-fishing zone. 

Non-commercial fishing includes subsistence fishing and recreational fishing. The prohibition on all 

fishing within 12 nmi of the Refuge will be reviewed by the Western Pacific Regional Fisheries 

Council and NMFS in 2016. Additionally, the areas of the Monument that are outside of the Refuge 

became part of the National Marine Sanctuary of American Samoa in 2012. 

Given the remoteness of Rose Atoll NWR, there is very little use of this area. However, Service staff 

have seen recreational sailboats accessing the area. In June 2009, the S/V Paul Eric entered the 

Refuge as an emergency stop to repair its engine. Unfortunately, as the vessel weighed anchor in 

preparation to depart, strong winds and currents pushed the vessel aground on the shallow eastern 

reef near Sand Island. During the removal of the Paul Eric from the reef, a second large yacht, the 

Southwest was seen approaching Rose from the south. Additionally, during a two day research visit 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 3. Physical Environment 3-13

in August 2012, one vessel that had entered the lagoon left after being informed that entrance was 

only by Special Use Permit, and two other vessels asked for permission to enter the lagoon but were 

denied. 

Surrounding land use: the Monument, Exclusive Economic Zone, and Large Fishing Vessel Exclusion Zone.

USFWS
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

3-14 Chapter 3. Physical Environment
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 4. Biological Environment 4-1 

Chapter 4. Biological Environment

This chapter addresses the biological resources and habitats found on Rose Atoll NWR. However, it 

is not an exhaustive review of all species occurring within the Refuge. The chapter begins with a 

discussion of biological integrity (historic conditions and ecosystem function), as required under the 

Administration Act. The bulk of the chapter is then focused on the presentation of pertinent 

background information for habitats used by each of the Priority Resources of Concern (ROC) and 

other benefiting species designated under the CCP. The background information includes 

descriptions, conditions, and trends of habitats and threats (stresses and sources of stress) to the 

habitats and/or associated ROC. This information was used to develop goals and objectives for the 

CCP. 

4.1 Biological Integrity Analysis

The Administration Act, as amended, directs the Service to ensure that BIDEH of the Refuge System 

is maintained for the benefit of present and future generations of Americans. The elements of BIDEH 

are represented by native fish, wildlife, plants, and their habitats, as well as those ecological 

processes that support them. The Refuge System 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 a refuge and in associated ecosystems that represent BIDEH. 

Biological integrity lies along a continuum from a completely natural system to a biological system 

extensively altered by considerable human impacts to the landscape (which includes seascapes). No 

modern landscape retains complete BIDEH. We strive to prevent the further loss of natural biological 

features and processes. Maintaining or restoring biological integrity is not the same as maximizing 

biological diversity. Maintaining biological integrity may entail managing for a single species or 

community at some refuges and combinations of species or communities at other refuges. 

Maintaining critical habitat for a specific endangered species, even though it may reduce biological 

diversity at the refuge scale, helps maintain biological integrity and diversity at the ecosystem or 

national landscape scale. 

On refuges, we typically focus our evaluations of biological diversity at the refuge scale; however, 

these refuge evaluations can contribute to assessments at larger landscape scales. We strive to 

maintain populations of breeding individuals that are genetically viable and functional. Evaluations 

of biological diversity begin with population surveys and studies of flora and fauna. The Refuge 

System’s focus is on native species and natural communities such as those found under historical 

conditions (BIDEH policy). However, given the likely impacts of climate change (e.g., SLR, ocean 

acidification, ocean temperature) on reefs and atoll islands, maintaining historic conditions may not 

be possible in the future. The Service will continue to promote resilience by minimizing other 

anthropogenic effects to the Refuge so the species and habitats have improved chances of adapting to 

a changing climate. Additionally, we will incorporate new climate science into our management as it 

becomes available. 

We evaluate environmental health by examining the extent to which environmental composition, 

structure, and function have been altered from historic conditions. Environmental composition refers 

to abiotic components such as air, water, and soils, all of which are generally interwoven with biotic 

components (e.g., decomposers live in soils). Environmental structure refers to the organization of 

abiotic components, such as atmospheric layering, aquifer structure, and topography. Environmental 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

4-2 Chapter 4. Biological Environment

function refers to the processes undergone by abiotic components, such as wind, tidal regimes, 

evaporation, and erosion. A diversity of abiotic composition, structure, and function tends to support 

a diversity of biological composition, structure, and function. 

Due to its remoteness and limited acreage, Rose Atoll is a far more natural system than most 

landscapes. The atoll has had very limited human contact and no development on it. Its distinctive 

CCA, declining Pisonia forest, terrestrial fauna, and unique assemblage of marine fishes and 

invertebrates in the lagoon are all critical components of BIDEH. The overarching BIDEH principles 

that were integrated into the CCP analysis included the Refuge purposes, Refuge System mission, 

and where appropriate, maintenance of BIDEH for wildlife and habitat, and BIDEH in a landscape 

context. The BIDEH for the Refuge is summarized in Table 4-1. 

Table 4-1. Biological Integrity, Diversity, and Environmental Health 

Habitats Population/Habitat 

Attributes

Natural Processes 

Responsible for These 

Conditions

Limiting Factors

Lagoon Lagoon floor (to ~98 feet 

depth) and back reef 

composed of carbonate sand 

and rubble, with low coral and 

CCA cover (< 1%). Hardsubstrate pinnacles and patch 

reefs with moderate coral and 

CCA cover (>10%), 

supporting diverse fish 

assemblage and faisua

Potential conservation 

species: faisua, sea turtles, 

candidate ESA coral species

Intact perimeter reef 

(present-day height, width, 

biotic construction) and ava 

(present-day depth, width, 

location unblocked flow) 

that regulate seawater 

exchange with surrounding 

ocean and seawater flow 

inside lagoon; natural 

breakdown of calcifying 

organisms providing 

carbonate sediment

Proliferation of cyanobacteria; 

illegal fishing and faisua 

poaching; reduced calcification 

linked to ocean acidification

Perimeter 

Crustose 

Coralline 

Algal Reef

Living reef dominated by 

CCA, with intact geomorphic 

structure providing mosaic of 

microhabitats for

invertebrates including corals 

and sea urchins

Potential conservation 

species: candidate ESA coral 

species

Growth of CCA and other 

calcifying organisms, and 

accretion of carbonate 

through biochemical 

processes, maintains 

constructional platform 

between open ocean and 

lagoon

Rate of SLR relative to natural 

capacities for growth and 

accretion; reduced calcification 

linked to ocean acidification;

overgrowth by non-reef-building

cyanobacteria

Ava Unobstructed channel 

between lagoon and fore reef 

with present-day depth, width, 

and location

Potential conservation 

species: faisua, sea turtles, 

candidate ESA coral species

Natural hydrological regimes 

of oceanic and lagoonal 

seawater flow

Impedance of natural flow 

patterns by boat grounding or 

other obstacles
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 4. Biological Environment 4-3 

Beach Strand Beach strand habitat clear of 

invasive introduced plants and 

marine debris that provides 

nesting sites for groundnesting seabirds and turtles 

and foraging sites for 

migratory shorebirds

Sand and rubble formed by 

the action of storms and bioerosion of living CCA reef 

community is deposited and 

re-arranged by ocean waves.

Plant community on the 

beach strand areas are kept at 

seral stage by repeated 

overwashing and storms

Current sea level

Nonnative invasive species of 

plants and animals; human 

disturbance and trampling; 

interruption in the supply of 

gastropod shells from the reef that 

are used by land hermit crabs; sea 

level rise; reduced calcification 

linked to ocean acidification; 

increased storm frequency and 

intensity changing sediment 

distribution patterns

Littoral 

Forest

South Central tropical Pacific 

littoral forest with a native 

species composition typical of 

other intact habitats of similar 

rainfall and soil type. This 

forest provides nesting sites 

for arboreal and groundnesting seabirds as well as 

native land crabs, insects, and

migratory shorebirds

Nutrient input from seabird

guano and precipitation 

favor pu’a vai and other 

species of plants dispersed 

by birds or ocean currents

Nonnative invasive species of 

plants, animals, and pathogens, 

human disturbance; SLR; reduced 

calcification linked to ocean 

acidification; increased storm 

frequency and intensity; changing

sediment distribution patterns

 

4.2 Selection of Priority Resources of Concern

4.2.1 Analysis of Priority Resources of Concern

Wildlife and habitat goals and objectives were designed directly around the habitat requirements of 

species designated as Priority ROC (ROC are called conservation targets in conservation planning 

methodologies used by other agencies and NGOs). As defined in the Service’s Policy on Habitat 

Management Plans (620 FW 1), resources of concern are: 

“all plant and/or animal species, species groups, or communities specifically identified in 

refuge purpose(s), System mission, or international, national, regional, state, or ecosystem 

conservation plans or acts. For example, waterfowl and shorebirds are a resource of concern 

on a refuge whose purpose is to protect ‘migrating waterfowl and shorebirds.’ Federal or 

State threatened and endangered species on that same refuge are also a resource of concern 

under terms of the respective endangered species acts (620 FW 1.4G)... 

Habitats or plant communities are resources of concern when they are specifically identified 

in refuge purposes, when they support species or species groups identified in refuge 

purposes, when they support NWRS resources of concern, and/or when they are important in 

the maintenance or restoration of biological integrity, diversity, and environmental health.” 

Therefore, ROC for a refuge may be a species or species group, or the habitat/plant community that 

supports a priority species/species group. 

In developing its listing of Priority ROC, the planning team selected not only species mentioned in 

establishing documents for the Refuge, but also species that captured the ecological attributes of 

habitats required by larger suites of species. The ecological attributes of habitats should be analyzed 

to meet the life-history requirements of ROC, and are therefore critical to sustain the long-term 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

4-4 Chapter 4. Biological Environment

viability of the ROC and other benefiting species. Ecological attributes of terrestrial habitats include 

vegetation structure, species composition, age class, patch size and/or contiguity with other habitats; 

hydrologic regime; and disturbance events (e.g., flooding, fire). Likewise, in the marine environment, 

ecological attributes include benthic structure; species composition and distribution; oceanographic 

regime (waves, tides, currents, upwelling); water quality parameters such as pH, temperature, 

salinity, light attenuation, nutrient levels; and disturbance events (e.g., tropical storms). These 

provide measurable indicators that strongly correlate with the ability of a habitat to support a given 

species. 

Tables listing the desired conditions for habitat types found on the Refuge incorporate “desired” 

conditions that were based on scientific literature review and team members’ professional judgment. 

These desired conditions for specific ecological attributes were then used to help design habitat 

objectives, as presented in Chapter 2. However, not all ecological attributes or indicators were 

deemed ultimately feasible or necessary around which to design an objective. Other factors, such as 

feasibility and the Refuge’s ability to reasonably influence or measure certain indicators, played a 

role in determining the ultimate parameters chosen for each habitat objective. Thus, ecological 

attributes should be viewed as a step in the planning process. The ultimate design of objectives was 

subject to further discussion and consideration. 

Limiting factors were also considered in developing objectives. A limiting factor is a threat to, or an 

impairment or degradation of, the natural processes responsible for creating and maintaining plant 

and animal communities. In developing objectives and strategies, the team gave priority to mitigating 

or abating limiting factors that presented high risk to ROC. In many cases, limiting factors occur on a 

regional or landscape scale and are beyond the control of individual refuges. Through the 

consideration of BIDEH, the Refuge will provide for or maintain all appropriate native habitats and 

species. Refuge management priorities may change over time, and because the CCP is designed to be 

a living, flexible document, changes will be made at appropriate times. 

Early in the planning process, the planning team cooperatively identified priority species for the 

Refuge, as recommended under the Service’s 620 FW 1. These ROC frame the development of goals 

and objectives for wildlife and habitat. The ROC may be species, species groups, or features that the 

Refuge will actively manage to conserve and restore over the life of the CCP, or species that are 

indicators of habitat quality for a larger suite of species. Negative features of the landscape, such as 

invasive plants, may demand Refuge management effort, but are not designated as ROC. 

The main criteria for selecting priority ROC included the following requirements: 

• The resource must be reflective of the refuge’s establishing purposes and the Refuge System 

mission; 

• The resource must include the main natural habitat types found at the refuge; 

• The resource must be recommended as a conservation priority in the Wildlife and Habitat 

Management Review; or

• The resource must be federally or State/Territory-listed as a candidate for listing, or a species 

of concern. 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 4. Biological Environment 4-5 

Other criteria that were considered in the selection of the resources of concern included the 

following: 

• Species groups or Refuge features of special management concern; 

• Species contributing to the BIDEH of the ecosystem; or 

• Species for which it is feasible to estimate population size (needed for future monitoring and 

adaptive management).

Table 4-2. Priority Resources of Concern

Focal Species Habitat Type Habitat Structure Life History 

Requirements

Other Benefiting 

Species

Pu’a vai 

(Pisonia) 

Littoral Forest Sandy and phosphate 

soils with elevation 

sufficient to avoid 

overwashing in all 

but the largest storms 

(> 6.6 feet)

All Tree-nesting seabirds 

fua’o (red-footed 

booby), atafa (lesser 

frigatebird), atafa (great 

frigatebird), gogo uli

(black noddy), white tern 

(manu sina)

Littoral forest 

tree species – 

Cordia 

subcordata, 

Tournefortia 

argentea, 

Hernandia 

nymphaeifolia, 

Terminalia 

samoensis, 

Neisosperma 

oppositifolium, 

and Hibiscus 

tiliaceus

Littoral forest

(mesic)

Sandy and phosphate 

soils with elevation 

sufficient to avoid 

overwashing in all 

but the largest storms 

(> 6.6 feet)

All Matu’u (Pacific reef 

heron) for nesting 

habitat and aleva (longtailed cuckoo) for 

wintering, molting, and 

foraging

Tava’e’ula (redtailed 

tropicbird) 

Littoral forest Ground under 

vegetation in 

understory and base 

of trees; sites that 

provide adequate 

shade for nestling for 

the duration of the 

growth period

Nesting Gogo (brown noddy), 

fua’o (brown booby)

Fua’o (redfooted booby)Littoral forest Tournefortia and 

Pisonia trees that 

provide appropriate 

structure for nest 

construction above 

the ground

Nesting Atafa (lesser 

frigatebird), atafa (great 

frigatebird), gogo uli

(black noddy)

Land hermit 

crabs Coenobita 

perlatus and 

Coenobita 

Littoral forest Sandy and phosphate 

soils, vegetation and 

shade protection from 

tropical sun

Reproduction – aquatic 

larvae, terrestrial adults, 

foraging, proximity to 

sea water source for 

Tuli prey upon land 

hermit crabs.

Entire forest community 

benefits from Coenobita
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

4-6 Chapter 4. Biological Environment

Focal Species Habitat Type Habitat Structure Life History 

Requirements

Other Benefiting 

Species

brevimanus osmoregulation and gill 

maintenance

acting as scavengers and 

nutrient recyclers

Gogo Uli (sooty 

tern)

Beach strand and 

littoral forest

Open beach habitat

or forest sites with 

minimal understory 

that provide open 

access for landing 

and takeoff and 

visibility for these 

highly social nesters

Nesting Gogosina (gray-backed 

tern), gogosina (blacknaped tern), tuli, ruddy 

turnstones that prey on 

sooty tern eggs

Tuli (bristlethighed curlew)Beach strand and

littoral forest

Open beach habitat

or open forest

Wintering, molting, 

feeding

Tuli (ruddy turnstone), 

tuli (sanderling), tuli 

(wandering tattler), tuli 

(whimbrel), tuli (Pacific 

golden plover)

I’a sa (green 

turtle) and 

laumei uga 

(hawksbill 

turtle)

Beach 

strand/littoral 

forest/lagoon

Sand with access to 

the water but above 

the high tide line

Nesting (green turtle 

only), resting, feeding

Tamole (yellow 

purslane, 

Portulaca lutea) 

Beach strand Open sand, no over 

story

All

Malie (gray reef 

shark) 

Lagoon, ava Pinnacles, patch 

reefs, back reefs

All Malie alamata (blacktip 

reef shark), whitetip reef 

shark (Triaenodon 

obesus), bumphead 

parrotfish, Maori wrasse,

gatala-uli (peacock 

grouper), leopard 

grouper, coral hind,

strawberry grouper,

mata’ele (flagtail 

grouper), honeycomb 

grouper, gatala-aloalo

(dwarf spotted grouper),

masked grouper

Amu (stony 

corals)

Acropora, 

Astreopora, 

Cyphastrea, 

Favia, 

Leptastrea, 

Montastrea, 

Montipora, 

Pavona, 

Platygyra, 

Reef crest, back 

reef, lagoon 

pinnacles, and 

patch reefs

Hard substrate, depth 

and water clarity 

sufficient for light 

penetration, moderate 

temperatures, 

seawater immersion 

time sufficient to 

prevent desiccation, 

low nutrients, low 

algae and 

cyanobacteria, 

herbivorous fish and 

All (growth, feeding 

[endosymbiosis, and 

plankton capture], 

reproduction)

Reef fish; other benthic 

invertebrates (soft 

corals, mollusks, 

crustaceans, worms, 

echinoderms, tunicates) 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 4. Biological Environment 4-7 

Focal Species Habitat Type Habitat Structure Life History 

Requirements

Other Benefiting 

Species

Porites, 

Psammocora, 

Stylocoeniella

spp.

invertebrates

Faisua (giant 

clam) (Tridacna 

maxima) 

Lagoon 

pinnacles and 

patch reefs

Hard substrate, water 

depth and clarity 

sufficient for light 

penetration 

All (growth, feeding 

[endosymbiosis, and 

filter-feeding], 

reproduction

Sea urchins

(tuitui) 

Reef crest, back 

reef, lagoon 

pinnacles, and 

patch reefs

Hard substrate, 

available holes for 

occupancy, algal 

films, and turf for 

grazing

All (growth, grazing, 

reproduction)

Corals, CCA

Turban shells 

(Turbo crassus, 

Turbo setosus, 

Turbo 

argyrostomus)

Reef and lagoon 

habitats

CCA reef flats with 

epilithic algae for 

grazing

Foraging (herbivores 

and detritus feeders)

Land hermit crabs 

(Coenobita perlatus and 

C. brevimanus) that use 

shells of these 

gastropods

Crustose 

coralline algae

(Porolithon

spp., 

Hydrolithon

spp.)

Reef Hard substrate, 

moderate 

temperatures, low 

cyanobacteria, 

herbivorous fish, and 

invertebrates

All (growth, 

photosynthesis, 

reproduction)

Stony corals

4.3 Habitat Types

An atoll is a reef formation atop a subsiding extinct volcano that includes a lagoon surrounded by a 

shallow perimeter reef, at least one emergent island, and regular surface water exchange between the 

lagoon and the open ocean (Woodroffe and Biribo 2011, Maragos and Williams 2011). Rose Atoll 

has all these major habitats and associated biological groups found on Pacific atolls. It supports 

island and marine species groups that are adapted to each of these habitats. 

All biological communities and habitats at Rose Atoll are profoundly influenced by the ocean and 

associated climate. The early life cycle stages of most reef species at Rose are tiny and moved by 

tides, waves, and ocean currents. Water quality, motion, temperature, light, salinity, and substrate 

characteristics influence the behavior of these small organisms causing them to settle on or near 

favorable habitats to begin the transition to adult phases. 
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4-8 Chapter 4. Biological Environment

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Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 4. Biological Environment 4-9 

Figure 4-1. Habitats. 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

4-10 Chapter 4. Biological Environment

The back sides of maps are blank to improve readability.
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 4. Biological Environment 4-11

4.3.1 Ava

The ava is a shallow (less than 50 feet) and narrow (130 feet) passage that connects the open ocean to 

the lagoon. The shape, size, and location of the ava is vital to maintaining the lagoon, reef, and island 

habitats. As ocean water spills into the lagoon over the sides of the reef, it is released out through the 

ava. Though water usually flows out the ava, tides and waves occasionally create a situation where 

water flows into the lagoon through the ava. A data-logging current meter deployed in the ava by 

NMFS PIFSC in 2002 showed that water flowed predominantly out of the ava from the lagoon, 

attaining flow rates of 3.3 knots, with only short periods of flow reversal (NMFS PIFSC unpubl. data 

2011). 

The elevation of the ava controls the water movement out of the lagoon, and plays a major role in the 

layering of lagoon water by temperature and salinity. Additionally, the shape and location of the ava 

is an important factor in the location and longevity of the islands on the atoll. Water movement inside 

the atoll creates currents that remove sand from some areas and deposit it in other areas. This 

sediment transport regime has created and maintained Rose and Sand Islands as dynamic islands in 

roughly the same location since Rantzau mapped Rose Atoll in 1873 (Rodgers et al. 1993). The ava 

is also the major passageway for fish and other organisms in and out of the lagoon, where species 

that require more shelter from rough water to breed or live may concentrate. Sharks and other 

predators congregate at the mouth of the ava waiting for prey. As such, the ava connects reef life on 

both sides of the perimeter reef at Rose Atoll.

In addition, the size and depth of the ava affect the amount of water exchange between the lagoon 

and the ocean, and indirectly the height and width of the perimeter reef crest and reef slopes 

surrounding the lagoon. In the case of Rose, the two islands are relatively small in relation to the total 

circumference of the open reef crests, allowing more water to enter the lagoon over the crests during 

high tides and heavy wave action. Because the ava is shallow and narrow, water exiting the ava is 

less than the amount of water entering over the perimeter reefs during tidal cycles. As a consequence, 

water levels in the lagoon remain higher than those on the ocean side except at the highest tides. This 

allows the perimeter reef crests to remain wet as water spills over them, and that allows the reef 

builders on the crests to grow slightly higher, to levels above mean low water. Over time, the crest of 

the perimeter reef can maintain itself above the surrounding ocean at low tides. As a result, water 

levels in the lagoon are higher than that of the surrounding ocean, and the quantity and velocity of 

water flowing “downstream” out the ava greatly exceeds that which enters the ava during rising tides. 

Thus, any modification of the ava, such as widening or deepening it to facilitate better or larger boat 

passage, or having a large vessel disabled and blocking the flow of water through the ava, can have 

drastic effects on the biology of the lagoon and kill the reef builders on the crests of the perimeter 

reefs. Widening or creating boat channels through atoll reefs have degraded the lagoons of Kanton 

Atoll in the Phoenix Islands, atolls in Tuvalu, and several other atolls (Carpenter and Maragos 1989, 

Kaly and Jones 1991, Maragos 1993, 2011a, 2011b) and even the lagoons in some NWRs such as 

Johnston Atoll, Midway Atoll, and Palmyra Atoll. 

The ava is used by Refuge staff to enter the atoll when conducting management. No active 

management of the ava is conducted other than regulating boat traffic through the pass. 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

4-12 Chapter 4. Biological Environment

4.3.2 Reef (Crest and Back) 

The reef crest at Rose Atoll, constructed by 

countless generations of calcifying marine 

organisms whose remains have been cemented 

together over time by biochemical processes, 

varies from 1,000 to 3,000 feet wide. The 

predominance of CCA was noted by early 

scientific visitors (Mayor 1921, Setchell 1924) 

and has been reiterated many times. The reef 

crest is the living veneer of the ancient physical 

barrier separating the deep surrounding ocean 

from the shallow interior lagoon. By breaking 

the force of waves and currents, the shallow reef 

crest provides a sheltered environment inside 

which lagoon habitats have developed, and itself harbors a biotic assemblage adapted to shallow 

intertidal conditions. This living platform, which continues to accrete with successive generations of 

calcifying organisms, is resistant to physical- and bio-erosion, enabling formation and maintenance 

of the marine and terrestrial lagoon habitats in which other organisms exist. The reef crest is a vital 

habitat for Pacific reef herons and snowflake eels. 

In the aftermath of the 1993 grounding, extensive damage resulted to CCA, corals, sea urchins, and 

other biota on the reef crest and neighboring lagoon back reef from mechanical abrasion and 

chemical release. Iron released by the deterioration of metallic debris stimulated cyanobacterial 

populations on the reef crest and neighboring back and patch reefs and caused them to spread to other 

parts of the atoll that were not directly affected by the grounding. Transects conducted on the reef 

crest from 1995 to 2010 showed continuing recovery of CCA cover. 

The perimeter reef includes the back reef which consists of unconsolidated terrain encircling the 

lagoon, composed largely of rubble that slopes from the reef crest to the more interior, sandier 

benthos. 

4.3.3 Lagoon 

Rose has an almost completely enclosed

lagoon, measuring less than 1.2 miles at its 

widest point, with only one ava at the 

northwest corner. Because the ava is shallow 

and narrow, the volume of water exiting the 

ava is less than the volume of water entering 

over the reef crest during tidal cycles. As a 

consequence, water levels in the lagoon remain 

higher than those on the ocean side except at 

the highest tides, and the volume and velocity 

of water flowing out the ava greatly exceeds 

that which enters at that site. 

Reef flat. Frank Pendleton/USFWS

Lagoon with pinnacle. Kelsie Ernsberger/USFWS

 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 4. Biological Environment 4-13

The lagoon includes the more finely divided “shallow lagoon,” “lagoon floor,” and “lagoon 

pinnacles.” Detailed bathymetry produced by NMFS PIFSC shows the lagoon floor maximum depth 

at 98 feet. Circulation and water mixing in tropical reef lagoons and back reef areas is restricted 

compared to neighboring fore reef slopes and surrounding oceanic surface waters. This restricted 

circulation frequently results in temperature differences of several degrees between the lagoon 

reservoir and the surrounding ocean. This effect is especially apparent in enclosed atoll morphologies 

during periods of high solar radiation and low winds. At Rose Atoll, interpolation of in situ surface 

water temperatures measured from conductivity/temperature/depth instruments and towed 

thermistors in February 2002 showed surface waters up to 5.5°F higher inside the lagoon and back 

reef areas compared to the cooler, relatively well-mixed waters in the fore reef area and surrounding 

ocean. Turbidity as indicated by short-term measurements of beam transmission was notably higher 

inside the lagoon compared with other areas outside the perimeter reef crest (NMFS PIFSC 2008). 

The lagoon also displayed higher values of Chlorophyll-a, NO2, and SiO2 when compared with the 

fore reef. Finally, the lagoon consistently registered the densest and most saline waters at Rose, 

especially below the sill depth (approximately 16 feet) of the ava. These elevated nutrient 

concentrations, coupled with increased or variable turbidity, suggest prolonged periods of mixing, 

flushing, and nutrient cycling within the 

surface-water layers of the protected shallowwater lagoon. 

Wave-induced lagoon circulation is tidally 

modulated as more wave set-up occurs during 

high tides and less during low tides. The net 

effect is that surface waters in the lagoon 

likely have a short residence time. The highsalinity and high-density subsurface waters in 

the lagoon, on the other hand, have no 

obvious means to circulate and flush out of 

the lagoon. Hence, lagoon bottom waters 

likely have much longer residence times. 

While much of the lagoon floor consists of 

unconsolidated sand and rubble (Kenyon et al. 

2010), a number of hard-bottom pinnacles are found rising toward the surface, providing substrate 

that supports corals, faisua, other macroinvertebrates, and diverse fish populations. Coral cover on 

the lagoon pinnacles is dominated by the genera Favia, Montipora, Porites, and Astreopora. Faisua 

density is highest at the base of the lagoon pinnacles. Small- to medium-sized fish are very abundant 

around several of the larger pinnacle patch reefs inside the lagoon, where parrotfish, snapper, 

emperor, goatfish, and jacks are common (NMFS PIFSC 2008). 

4.3.4 Intertidal

The north end of Rose Island is characterized by an expanse of sand and rubble that is exposed at low 

tide. Large groups of terns (primarily brown noddies and sooty terns) form “clubs” here when the 

area is exposed, possibly because it is not being used for nest territories and offers good visibility for 

quick escape. Seabird clubs are ephemeral single-species groups of birds that congregate and 

socialize or rest together. Shorebirds such as wandering tattlers and ruddy turnstones also forage on 

the exposed sediment. When the tide comes in reef fish move in as well to forage in the shallow 

water.

Coral cover on the lagoon pinnacles is dominated by the genera 

Favia, Montipora, Porites, and Astreopora. 

Jean Kenyon/USFWS
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

4-14 Chapter 4. Biological Environment

Beach strand at Rose Island. 

Kelsie Ernsberger/USFWS

4.3.5 Beach Strand 

Whistler (1992) defines littoral/herbaceous strand (part of beach strand) as a narrow zone of 

vegetation occupying the upper portion of sandy or rocky beaches, limited inland by littoral forest or 

littoral shrubland, and seaward by the high-tide mark of the ocean. Littoral strand occupies the 

transition zone between the sea and the forest 

(Amerson et al. 1982). This community is 

dominated by herbaceous creeping vines, and 

shrubby species up to 6.5 feet or more in height 

(sometimes prostrate or dwarfed by the strong, 

salty sea winds). It also includes strand species 

found on coasts with exposed rocks within, or 

beyond, the reef (Amerson et al. 1982). The beach 

strand habitat is a harsh environment, subjected to 

dry conditions, high temperatures, salt spray, or 

occasional inundations by salt water. In addition, 

plants in this community must grow in direct 

tropical sunlight and grow on poor sandy or rocky 

soil.

Beach strand habitat is a result of dynamic, natural processes of waves washing away and rebuilding 

sediment on both Rose and Sand Islands. On Sand Island the habitat is often devoid of vegetation or 

sparsely vegetated while on Rose Island the habitat supports Tournefortia argentea (tree heliotrope) 

shrubs. The beach strand vegetation on Rose Island is dominated by Boerhavia repens and 

historically also consisted of tamole (Portulaca lutea) (Amerson et al. 1982, IUCN 1991, Setchell 

1924). It is presently confined to a single boulder in the reef crest. These large coral blocks thrown 

up by extreme storm events serve as roosts for Pacific reef herons and brown boobies. It is likely that 

seeds of additional species regularly wash up on the beach and then die back as storm surges wash 

them away. In 1921 when Mayor described the atoll, Sand Island had absolutely no vegetation; 

however, some species would be established periodically until the next storm waves washed them 

away. 

Some native ground-nesting seabirds (i.e., sooty terns) thrive in this open habitat. Sooty terns, brown 

noddies, gray-backed terns, and black-naped terns use (mainly for nesting) the beach strand habitat 

on Rose and Sand Islands. Rose Atoll beach strand habitat is an important foraging, resting, and 

Portulaca lutea growing on a block at Rose Atoll. Jiny Kim/USFWS
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 4. Biological Environment 4-15

molting ground for six migratory shorebirds: the ruddy turnstone, sanderling, wandering tattler, 

whimbrel, bristle-thighed curlew, and the Pacific golden plover. Ghost crabs forage and dig their 

burrows in the beach strand and Coenobita (hermit) crabs traverse the sand at night to get to the 

water’s edge for hydration. Due to overharvest, loss of beach habitat, incidental kills in fishing gear, 

and other reasons, green turtle numbers have declined worldwide and the beach strand at Rose Atoll 

provides a vital nesting area for this species. Present management of the beach strand includes 

removing marine debris and looking for and controlling invasive plants. 

4.3.6 Littoral Forest

Littoral forest is a common vegetation type occurring on tropical shores. It often consists of a dense 

forest dominated by a single tree species. The major factor determining the distribution and extent of 

littoral forests is the ocean. Common characteristics for tree species in the community include 

tolerance of bright sunny conditions, dispersal by buoyant, salt-tolerant seeds (or hitchhiking on 

seabirds), and tolerance to salt spray and wind. However, most species are not tolerant of standing 

water or frequent incursions of saltwater (Amerson et al. 1982). Typically, the forest floor is open 

due to the lack of bright sunlight required for germination and growth of most herbs and shrubs on 

the beach strand (Whistler 1992). The limiting factor for tree species is substrate and soils (Amerson 

et al. 1982). The dominant tree species of Samoa include: Barringtonia asiatica and Calophyllum 

inophyllum in certain beach areas and historically pu’a vai on Rose Atoll. But other tree species that 

may also thrive in this forest type include Hernandia nymphaeifolia, Terminalia catappa, Cordia 

subcordata, Neisosperma oppositifolium, Guettarda speciosa, Thespesia populnea, Tournefortia 

argentea, and Cocos nucifera. Although common and sometimes dominant on Polynesian shores, 

coconut trees have presumably been planted or are remnants of former cultivation due to their 

presence mostly in or near villages and coastal plantations.

A map made in 1839 shows Rose Island extended across the width of the atoll rim and was covered 

by forests (Keating 1992). When Alfred Goldsborough Mayor did the first scientific account of Rose 

Atoll in 1920, he found the southern and southeastern half of Rose Island covered with a dense pu’a 

vai-dominated forest, with no other understory plants, except a single coconut tree. The largest trees 

were found near the southern end of the forest. Plant observations from 1974 to 1988 have 

documented at least 10 additional species that were established at one point (Wegmann and 

Holzwarth 2006). However, during the visit in 2010, eight species (Boerhavia repens, Tournefortia 

argentea, Pisonia grandis, Portulaca lutea, Hibiscus tiliaceus, Nephrolepis hirsutula, Cocos 

nucifera, Cordia subcordata) were documented. Appendix A lists the plant species of Rose Atoll, 

collections or first observations, and most recent information about current presence or absence. Rose 

Left photo: Boerhavia. Jiny Kim/USFWS

Middle photo: Seabirds using beach strand habitat. Jiny Kim/USFWS

Right photo: Coenobita crab. Kelsie Ernsberger/USFWS
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

4-16 Chapter 4. Biological Environment

Atoll’s littoral forest is currently dominated by Tournefortia argentea which forms a forest up to 25 

feet tall. Historically Rose Island supported a mature stand of pu’a vai. 

Pu’a vai (Pisonia grandis), found almost exclusively in Indo-Pacific islands from tropical Africa to 

eastern Polynesia and Micronesia, is spread by sticky fruits that become attached to seabirds. It is a 

shade-intolerant plant that thrives on sandy shores and islands, particularly in soil enriched with 

guano from seabirds. The distinct soil in the Pu’a vaigrove on Rose Island consists of an upper layer 

of rich chocolate-colored humus, which extends to over 6 feet in depth (Mayor 1921, Lipman and 

Taylor 1924) overlying the calcium carbonate bedrock. Pu’a vai is considered “one of the most salttolerant plants of which we have record at present” that is able to inhabit the unusually high salt 

concentrations in the soil on Rose Island (Lipman and Shelley 1924). The lack of fresh surface water 

and the properties of the soil most likely explain the limited number of plant species that are on the 

atoll (Amerson et al. 1982). 

Pisonia forests are declining throughout the Pacific. Historically, the best example of a Pisonia forest 

in American Samoa, Rose Island’s Pisonia forest has undergone several gradual periods of dieback 

and regeneration. The dieback was noted in the early 1970s but the forest was regenerating by 1976 

(Amerson et al. 1982). The cause of this dieback was unknown, but thought to be disease, drought, or 

an insect attack (Amerson et al. 1982). First documented in 2002, the soft scale insect (Pulvinaria 

urbicola) is associated with the once healthy forest’s decline (Wegmann and Holzwarth 2006). In 

May 2004, 10 of the remaining 11 mature Pisonia

trees were treated with injections of a systemic 

pesticide called imidacloprid (Trade name Imicide

®). Loss of trees continued so it appears the response 

may have come too late and this approach alone has 

not significantly deterred the scale infestation. Scale 

insect infestation is associated with significant loss of 

Pisonia forests worldwide (Queensland Parks and 

Wildlife Service 2006, 2007). Additionally, since the 

Polynesian rat was eradicated in 1993 coconut palms 

have been released from rat herbivory and have 

increased to a population size that threatens to shade 

out recruitment of native canopy trees. 

Left photo: Rose Island from the sea in 1939, dominated by pu’a vai. National Archives

Right photo: Rose Island from the lagoon in 2007 with just a few unhealthy trees remaining. USFWS

Scale insect on Pisonia leaf. 

Kelsie Ernsberger/USFWS
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 4. Biological Environment 4-17

The Pisonia trees along with tree heliotrope serve as important nesting and roosting habitat for the 

red-footed booby, great and lesser frigatebird, gogo uli , and white tern, which prefer to nest above 

the ground on trees. Tree heliotrope also provides cover for red-tailed tropicbirds, brown noddies, 

sooty terns, and brown boobies, which nest directly on the ground. Shrubs and rock piles also provide 

shade and daytime cover for the numerous land hermit crabs that inhabit the island. Thick vegetation 

and rock crevices also provide shelter and protection for the largest land crab, the coconut crab 

(Birgus latro). This species seems to have increased in density since the eradication of rats at Rose 

Atoll. The relatively open understory of the Pisonia forest is also favored habitat for Pacific goldenplovers, wandering tattlers, and ruddy turnstones (Engilis and Naughton 2004). Littoral forests were 

at one time a common habitat in the Pacific; however, human alteration of island landscapes has 

limited this forest type. The eradication of rats from Rose Atoll by 1993 provides important habitat 

for plant species that will be able to recolonize the atoll and perpetuate the littoral habitats that are in 

decline throughout the Pacific region. 

4.4 Threatened, Endangered, and Sensitive Species

One goal of the Refuge System is “to conserve, restore where appropriate, and enhance all species of 

fish, wildlife, and plants that are endangered or threatened with becoming endangered.” In the policy 

clarifying the mission of the Refuge System, it is stated, “we protect and manage candidate and 

proposed species to enhance their status and help preclude the need for listing.” In accordance with 

this policy, the CCP planning team considered species with Federal or State/Territory status, and 

other special status species, in the planning process. 

4.4.1 Tuli’olovalu (Numenius tahitiensis) or Bristle-thighed Curlew 

Tuli’olovalu breed in western Alaska and migrate during the winter to remote, small islands and 

atolls in the tropical Pacific Ocean (Marks and Redmond 1994). The beaches and littoral forest of the 

atoll are important wintering ground for tuli’olovalu . This rare shorebird is the only migratory 

species whose entire population is restricted to the insular Pacific (Hayman et al. 1986, Marks et al. 

1990). Marks and Redmond (1996) documented the strong fidelity shown by tuli to wintering sites. 

At Laysan Island in the Northwestern Hawaiian Islands (NWHI), only 1 of 16 marked adult 

tuli’olovalu changed its wintering home range area in 3 years of study (Marks and Redmond 1996). 

This species undergoes a molt-induced flightless period (unique in shorebirds) and leaves many birds 

more susceptible to predatory attacks during that time (Marks 1993, Marks and Redmond 1994). 

Therefore, predator-free islands to which these birds are adapted have become increasingly important 

as competition for space increases and less habitat is available due to an increasing human 

population. With a global population of approximately 10,000 individuals (Morrison et al. 2006), the

Service (USFWS 2008) has designated the curlew as a Bird of Conservation Concern and it is also 

ranked as Vulnerable by the International Union for Conservation of Nature (IUCN) (Engilis and 

Naughton 2004, IUCN 2008). It is also highlighted as a globally threatened species in need of 

regional action by the South Pacific Regional Environmental Programme. 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

4-18 Chapter 4. Biological Environment

I’a sa swimming in Rose Atoll lagoon. 

Kelsie Ernsberger/USFWS

4.4.2 Tuli (Pluvialis fulva) or Pacific Golden Plover

The Pacific golden plover breeds in western Alaska and Siberia and winters throughout the Pacific 

Islands. Plovers foraging at Rose Atoll likely come from the Alaskan breeding population, however, 

these affinities are still poorly understood (Engilis and Naughton 2004). Tuli are widespread across 

the Pacific region in any open habitat from beach strands to upland pastures, occurring in good 

numbers on remote islands and atolls. Amerson et al. (1982) estimated 4,500 tuli in American 

Samoa, a small population number relative to the total United States Pacific Islands (USPI) 

populations (Engilis and Naughton 2004). Johnson et al. (2008) studied migration behavior of Pacific 

golden plover in American Samoa and were able to confirm that at least 1 of the 30 birds they tagged 

on Tutuila Island was breeding in Alaska. The birds departed Samoa for the northward migration in 

mid-April. The return of the plovers began in late August and peaked in mid-September. This 

represents at least a 5,594-mile trip from American Samoa. Johnson et al. (2008) estimated there 

were 500 tuli on Tutuila. The largest count of tuli recorded at Rose Atoll was 49 individuals in 1984. 

The USPI Regional Shorebird Conservation Plan identified the Pacific Golden Plover as a species of 

High Conservation Concern (Engilis and Naughton 2004).

4.4.3 I’a sa (Chelonia mydas) or Green Turtle

I’a sa is listed as threatened under the ESA. Adults can weigh up to 500 pounds and are often found 

living near tropical reefs and rocky shorelines. Females may lay up to 6 clutches per season in pits 

excavated in soft beach sand, with each clutch containing about 100 eggs. Hatchlings and juveniles 

live in pelagic waters. 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; their common name is derived from the color of 

the animals’ body fat, which is green from the marine algae and sea grasses they eat. 

I’a sa use the protected habitats of Rose Atoll for 

feeding and nesting. Their numbers have declined 

throughout the south Pacific due to the combined 

effects of habitat destruction, human harvest for 

meat and shells, depredation by introduced 

predators, and incidental drowning in fishing gear 

(Kinan 2005, Craig 2002). The isolated beaches on 

Rose Atoll provide an important nesting ground for 

i’a sa. The number of i’a sa nesting annually at Rose 

Atoll has been estimated at 24–36 (Tuato’o-Bartley 

et al. 1993). However, the total number of i’a sa

using Rose Atoll as a nesting ground could actually 

be several fold higher, since females only nest every 

2–5 years (Spotila 2004, NMFS and USFWS 

1998a), and thus a different set of turtles nest each season. Given the scarcity of beaches where 

turtles can nest and their eggs hatch unmolested, the value of the isolated beaches at Rose Atoll is 

considerable, even if only 120 or so i’a sa nest there.

The Historical Summary of Turtle Observations at Rose Atoll, American Samoa, 1839–1991 (Balazs 

1991) is a compilation of historical data and notations. The document lists a total of 47 entries for 

that time period, most of the earlier ones simply report presence or absence of turtles. From 1970 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 4. Biological Environment 4-19

onward, turtle observations were more quantitative, if no less sporadic and opportunistic due to the 

expense of reaching the remote atoll. Aerial, land-based, and water-based surveys recorded the 

number of turtles, their tracks, nest pits, eggs, hatchlings, and nesting and mating behaviors (Balazs 

1991). An estimated 200 turtles were seen in the lagoon during an aerial survey in August 1974, the 

highest value recorded. A total of 406 pits were counted on both Rose and Sand Islands during a 

survey in October 1976. A decade later, in fall 1985, biologists counted a total of 244 pits on both 

islands, and a decade after that, in fall 1992, the total count was 81 nesting pits. However, the 

problem with nest pit counts is that female turtles often dig test pits before actually laying eggs, and 

they lay multiple clutches the year they make the long migration to their natal nesting beach. Also, 

unless there is a major storm event that wipes the beach clean, it is difficult to reliably discern if a pit 

was dug that season or the season before (Ponwith 1990). These limitations, as well as uneven survey 

effort, should be taken into account when comparing pit counts from various years, and it should be 

recognized that pit counts are not the equivalent of a population count.

The i’a sa that visit Rose do so seasonally for reproduction, and spend the rest of their time in other 

parts of the south Pacific. Metal flipper tags were applied to a total of 46 nesting females from 1971 

to 1996 in order to see where they traveled (Balazs 1991). Three of these tags were re-sighted after 

the turtles were killed for food or fatally injured from a hunting attempt. Two were located in Fiji at 

the time of tag recovery and one in Vanuatu (both island groups to the west of Samoa). A fourth 

turtle was re-sighted at Rose Atoll, 9 years after she was initially tagged (Ponwith 1990), making 

multiple visits to the beach to nest.

Given the limited re-sighting rate of flipper tags, satellite tagging was subsequently employed in an 

effort to better comprehend the migration routes of green turtles in the south Pacific (Craig et al. 

2004). Seven females at Rose Atoll were outfitted with satellite tags during the nesting seasons of 

1993 to 1995. After 2 months of nesting at Rose, six of the turtles traveled to feeding grounds in Fiji. 

The seventh turtle traveled due east to Raiatea, an island in French Polynesia. The turtles’ migration 

route crossed 994 miles of ocean and took an average of 40 days. The route followed prevailing 

surface currents as recorded by satellite-linked ocean drifters deployed from Rose in February 2002, 

though the drifters traveled more slowly (net rate of 1.0 foot per hour) than the turtles (3.6 feet per 

hour). While these i’a sa spend the majority of their life in Fiji, accumulating the fat stores that will 

enable them to reproduce, the remote beaches at Rose Atoll provide invaluable undisturbed nesting 

habitat (Craig et al. 2004). 

Unlike many places in their range, at Rose Atoll, turtles can approach the beach without risk of being 

harvested for meat or drowned in nets, and eggs and hatchlings are free from depredation by wild 

pigs, rats, dogs, and humans. Marine debris can also prove deadly when it entangles turtles or is 

mistaken for food and ingested. Plastics are particularly harmful as they may remain in the turtle’s 

stomach for long periods of time, releasing toxic substances, and can clog the digestive system. 

Natural predators and dangers inherent to the human populated areas east of Samoa where the turtles 

feed continue to impact turtle populations. Craig et al. (2004) stresses the importance of working 

towards protection for turtles in their foraging waters east of Samoa, since this is where turtles spend 

90% of their adult life. Continued monitoring of the nesting beaches at Rose Atoll will give 

researchers a proxy for population trends of i’a sa in the region. 

4.4.4 Hawksbill Turtle (Eretmochelys imbricata) 

Hawksbill turtles use the protected habitats of Rose Atoll. Similar to i’a sa, their numbers have 

declined throughout the south Pacific, reduced by the combined effects of habitat destruction, human 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

4-20 Chapter 4. Biological Environment

harvest for meat and tortoise shell, depredation by introduced predators, and incidental drowning in 

fishing gear (Kinan 2005; Craig 2002). Although it is not clear if hawksbills nest at Rose Atoll, they 

are consistently sighted using the lagoon and open water habitats around the atoll. 

The hawksbill turtle is listed as endangered under the ESA. It is one of the smaller 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. Hawksbill turtles use different habitats at different stages of their life cycle, but are 

typically found around coastal reefs, rocky areas, estuaries, and lagoons. Their narrow head and jaws, 

shaped like a beak, allow them to get food from crevices in tropical reefs. They eat sponges, 

anemones, squid, and shrimp. Hawksbills have been consistently reported at Rose Atoll in historical 

accounts (Setchell 1924), as well as more recent surveys (Sekora 1974, Ludwig 1981, Amerson et al. 

1982, Morrell et al. 1991, Flint 1992, NMFS PIFSC 2006).

4.4.5 Faisua (Tridacna maxima) or Giant Clam 

The colloquial term “giant clam” refers to eight species of marine bivalves found in two genera 

(Hippopus and Tridacna) of the molluscan subfamily Tridacninae. Surveys of faisua populations at 

Rose Atoll have identified a single species, Tridacna maxima (Wass 1981, Green and Craig 1999). 

Less than a third of the size of the “true” giant clam Tridacna gigas, T. maxima is commonly referred 

to as the “small giant clam,” with shells generally not exceeding 9 inches in length. Found living on 

the surface of reefs or sand, or partly embedded in coral, the faisua occupies well-lit areas, due to the 

symbiotic relationship with single-celled photosynthetic algae (zooxanthellae) found in its fleshy 

mantle that require sunlight for energy production. Faisua also filter-feed on phytoplankton extracted 

from seawater siphoned through their body. 

Mature faisua are hermaphrodites that reproduce by broadcast spawning, releasing sperm first, 

followed by eggs. The fertilized egg develops into a larva within 3 hours and passes through two 

additional larval stages before undergoing metamorphosis after 8-10 days into a juvenile, sessile 

faisua that acquires zooxanthellae. Reproductive 

and growth studies at Rose Atoll (Radtke 1985) 

showed the clams reach maturity at about 10 

years of age corresponding to a shell size of 3–5 

inches. Young faisua are male and put most of 

their energy into growth, becoming 

hermaphrodites upon maturity and accompanied 

by a slower growth phase. Reproduction is 

stimulated by the lunar cycle, the time of day, 

and the presence of others eggs and sperm in the 

water. Faisua lifespan at Rose Atoll is estimated 

to be approximately 28 years. 

Tridacna maxima has the widest geographic 

range of all giant clam species. It is found in the 

oceans surrounding east Africa, India, China, 

Australia, Southeast Asia, and the islands of the Pacific. Although classified as Least Concern on the 

IUCN Red List, this culturally and ecologically important marine animal has declined precipitously 

from overharvesting in many populated areas including the high islands of American Samoa, but 

Faisua (Tridacna maxima) embedded in Astreopora coral. 

Kelsie Ernsberger/USFWS
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 4. Biological Environment 4-21

remains abundant at Rose Atoll (Green and Craig 1999). Tridacna maxima is listed under Appendix 

II of CITES meaning it is not necessarily threatened but that trade must be controlled in order to 

avoid use incompatible with its survival.

The first survey of faisua at Rose was undertaken by the American Samoa DMWR in an attempt to 

quantify the resource in response to requests by the Samoans that they be allowed to harvest the 

clams (Wass 1981). The study found faisua to be uncommon in the ava and fore reef but abundant in 

the lagoon. Distribution in the lagoon was patchy, with faisua abundant on solid substrate in the 

shallow, relatively clear parts of the lagoon, but with lower densities in the southern lagoon and 

below approximately 45 feet where water became more turbid. Constraints of time as well as the 

uneven distribution of suitable clam substrate in the lagoon made density determinations difficult, 

with the single transect survey in the southwestern lagoon yielding an average density of 0.33 clams 

per square yard. Size frequency data were collected at four lagoon locations; shell measurements 

ranged from 0.4 to 9 inches, with approximately 31% being greater than 5.5 inches, the size at which 

all clams are fully hermaphroditic. 

More extensive transects by Radtke (1985) in various habitats showed marked differences related to 

depth and substrate. Lagoon patch reefs in 20–40 feet of water were concluded to be prime habitat 

for faisua, with densities of 3.6–7.2 clams per square yard and 40–50% of the area colonized. Smaller 

coral patches (with up to 3.6 clams per square yard) and lagoon substrate (with up to 6 clams per 

square yard) were colonized at approximately 20%. Shell measurement ranged from 0.4 to 9 inches, 

with bimodal peaks around 1–2 inches and 6–7 inches. Radtke’s total estimated number of faisua in 

the lagoon was approximately 1,338,000. Unlike Wass (1981) Radtke did not favor controlled 

harvesting, stating, “they have a respectable number of organisms in this ecosystem, but due to their 

slow growth would have a small sustainable yield ... quantitative balance of production of Tridacna 

maxima at Rose Atoll does not appear to be within the scope of rational exploitation and exploitation 

could endanger the perpetuity of the unique environment.” 

A pivotal study by Green and Craig (1999) highlights the importance of Rose Atoll as a refuge for 

faisua. From 1994 to 1995 they surveyed all 6 islands of American Samoa and recorded a total of 

2,853 clams in survey transects, 97% of which were found at Rose. The majority were located in the 

lagoon, with faisua favoring areas at the base of pinnacle patch reefs. Roughly a quarter of the clams 

were mature in size, and mortality was estimated as being very low, due mostly to natural causes. 

The largest clam recorded was 11 inches across the widest part of the shell. Given the mean density 

of faisua, the population at Rose was estimated to be approximately 27,800 clams. The dramatically 

lower estimate than that provided by Radtke (1985) was considered to be the result of differences in 

sampling design rather than a population decline. The authors theoretically considered Rose to be a 

potential source of faisua recruits to other islands in the Samoan archipelago, given larval longevity 

(approximately 8 days, range 5–15 days) and water currents flowing westward from Rose at 16 miles

per day. 

Towed-diver surveys conducted by NMFS PIFSC in 2006 recorded more than 1,100 giant clams on 

30 linear miles of transect, with approximately 95% recorded on reefs inside the lagoon (NMFS 

PIFSC 2006). Researchers have noted that the pinnacle just inside the ava had a markedly lower 

density of faisua than the rest of the lagoon and it seems likely that this is where illegal harvesting 

has taken place (Wegmann and Holzwarth 2006). 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

4-22 Chapter 4. Biological Environment

4.5 Seabirds 

Rose Atoll’s importance to seabirds in the South central Pacific is disproportionately large relative to 

the size of its islands because some of the seabird species have been extirpated on most other islands 

in the region. There are very few uninhabited islands in the region so Rose provides breeding habitat 

for species that do not thrive in proximity to human settlements. Seabirds and migratory shorebirds 

are the numerically dominant terrestrial vertebrates. Since 1975, 16 species of seabirds have been 

recorded on land and 12 species are known to breed there. Efforts to eradicate the island of 

Polynesian rats began in 1991, with eradication declared in 1993. This enhanced the value of the atoll 

for seabird conservation and has increased the possibilities that other Pacific seabird species that are

currently threatened from habitat loss, predation, and invasive species, such as ta’i’o (wedge-tailed 

shearwaters), Christmas shearwaters, Bulwer’s petrel, Phoenix petrel, and the Polynesian storm 

petrel, might someday colonize the site. Social attraction methods may accelerate or facilitate this 

process of recruitment. Rose Atoll falls into the North American Bird Conservation Region called 

“Other U.S. Pacific Islands” and is now considered separately from sites in the Caribbean (USFWS

2008). 

For most if not all of the seabirds, listed terrestrial threats such as habitat destruction, invasive weeds,

disturbance, ungulates, and introduced predators limit populations (Metz and Schreiber 2002). 

Introduced predators such as rats, mongooses, and cats have reduced populations at many sites 

worldwide (Harrison 1990). 

Seabirds using terrestrial habitats at Rose Atoll all forage in the pelagic zone typically in association 

with large epipelagic subsurface predators such as skipjack (Katsuwonus pelamis) and yellowfin 

tunas (Thunnus albacares). These fish concentrate and force prey to the surface in the course of their 

own foraging and also make it available to foraging seabirds (Au and Pitman 1988). El NiñoSouthern Oscillation conditions can cause total or partial breeding failure in some locations 

(Schreiber and Schreiber 1989, Schreiber 1994, Orta 1992b) when changes in the temperature of 

water masses in proximity to the breeding sites change and force tuna to move elsewhere to find their 

preferred thermal conditions. A reduction in the biomass of these subsurface predators may render 

the preferred prey of tropical pelagic seabirds unavailable or difficult for the birds to detect. The 

relationships between these species is complex and poorly understood but it is a reasonable 

probability that exploitation of populations of large epipelagic fish by fishing may also affect the 

breeding success and survival of seabirds at Rose Atoll by reducing opportunities for this type of 

feeding interaction. The trophic relationships and effects on reproductive performance in this 

complex system have not been well quantified. 

4.5.1 Tava’e’ula (Phaethon rubricauda) or Red-tailed Tropicbird 

The tava’e’ula is a medium-sized bird with shining pinkish-white feathers and red tail plumes. They 

breed mainly on oceanic islands and coral atolls in the Indian and Pacific oceans. Breeding adults are 

mostly sedentary; however, they avoid land when not breeding and are among the most pelagic and 

solitary of seabirds (Schreiber and Schreiber 1993, Harrison 1990, Harrison et al. 1983). At sea, 

tava’e’ula are evenly distributed throughout their range (Schreiber and Schreiber 1993, King 1970). 

Little is known about their movements outside the breeding season. 

The world population is estimated at 17,000–21,000 pairs; with an estimated 12,000–14,000 pairs in 

the Pacific (Schreiber and Schreiber 1993, Gould et al. 1974). Small colonies exist in American 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 4. Biological Environment 4-23

Samoa and other remote Pacific islands. The largest number of active nests observed at Rose on any 

particular visit was 38 in 2002. The world population seems stable in many areas and may be 

increasing in some areas, but there is a lack of information on past population estimates so 

comparisons are difficult (Schreiber and Schreiber 1993). Within the USPI, tava’e’ula populations 

appear stable overall. 

Tava’e’ula nest on the ground under vegetation in the understory and base of trees, among rocks, 

roots, or logs and less commonly in the cavities of cliff faces (Schreiber and Schreiber 1993, Orta 

1992a). At Rose, red-tailed tropicbirds choose to nest under Tournefortia or Pisonia (Morell and 

Aquilani 2000). Nests are scrapes that vary from a shallow depression in the sand to more elaborate 

structures consisting of twigs and leaves (Schreiber and Schreiber 1993, Harrison 1990, Fleet 1974). 

Breeding occurs annually, but timing varies depending on locality (Schreiber and Schreiber 1993, 

Harrison 1990). First breeding usually occurs around 2–4 years (Schreiber and Schreiber 1993, 

Harrison 1990). The oldest-living bird recorded was 23 years (Klimkiewicz and Futcher 1989). 

Tava’e’ula are attracted to ships, presumably because flying fish, their main prey, are scattered by 

ships (Harrison et al. 1983). Previously the tava’e’ula also nested on Tutuila, however the abundance 

of introduced animals such as rats, cats, and dogs that attack ground-nesting birds likely led to their 

extirpation. Introduced ants have been recorded attacking incubating adults, chicks, and eggs at some 

colonies in the Pacific. 

4.5.2 Atafa (Fregata minor) or Great Frigatebird

The atafa has a pantropical distribution that overlaps with lesser frigatebirds (Orta 1992b) and breeds 

mainly on small remote islands, typically within regions with tradewinds in the tropical Atlantic, 

Indian, and Pacific Oceans. At sea, birds can be found any distance from land but they are most 

abundant within 50 miles of breeding and roosting sites (King 1967). Adults, juveniles, and 

nonbreeders disperse widely throughout the tropical seas. 

The world population is estimated at 500,000-1,000,000 birds (Orta 1992b). A small population of 

fewer than 50 pairs nests on Rose Island. They are colonial nesters, often constructing platform nests 

in the tops of bushes and trees. At Rose Island they nest in Tournefortia and Pisonia trees. Breeding 

occurs throughout the year depending on locality, with egg laying primarily in the dry season (Orta 

1992b). Great frigatebirds are sexually dimorphic; females tend to be 25% heavier than males (Orta 

1992b) and males are almost entirely black, with varying amounts of dark metallic green and purple 

feathers and a large, red gular pouch that they 

inflate during courtship. Females are black with a 

white breast patch. Atafa are seasonally 

monogamous; it is extremely rare for pairs to 

remain together for subsequent breeding attempts 

(Orta 1992b). Females breed biannually, 

sometimes every 3–4 years (Orta 1992b). Postfledging care, which continues for up to 18 

months, is provided by females. Sexual maturity 

begins around 8–10 years and most birds return to 

the natal colony to breed (Orta 1992b). 

Atafa usually feed in mixed-species flocks over 

tuna schools (Orta 1992b, King 1967). Their diet 

Atafa. Jim Maragos/USFWS
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

4-24 Chapter 4. Biological Environment

consists mostly of flying fish and squid which they capture at or above the water’s surface (Harrison 

et al. 1983). Frigatebirds are notorious for their kleptoparasitism (a form of feeding where one animal 

takes prey from another that has caught or killed it), but most of their food is obtained by fishing 

(Harrison et al. 1983). Tuna fisheries exploitation likely could lead to the decrease in availability of 

prey for atafa (Metz and Schreiber 2002). 

4.5.3 Atafa (Fregata ariel) or Lesser Frigatebird

The lesser frigatebird is also called atafa and has a pantropical distribution that coincides with, but is 

smaller than, that of the great frigatebird (Orta 1992b, Clements 2000). At sea, birds are most 

abundant within 50 miles of breeding and roosting islands although they can be found any distance 

from land (King 1967). Juveniles and nonbreeders disperse throughout tropical seas (Harrison 1990). 

The species’ world population is estimated at several hundred thousand birds (Orta 1992b). Small 

colonies exist in American Samoa (Amerson et al. 1982) with fewer than 100 pairs nesting at Rose 

Atoll. Within the USPI, lesser frigatebird populations have significantly declined due to the 

introduction of cats and rats; however, eradication of cats at Howland Island and Jarvis Island NWRs

seems to have resulted in an increase in lesser frigatebird populations at those sites (USFWS 2005, 

Rauzon et al. 2011). Human exploitation of tuna fisheries could potentially affect prey availability 

for lesser frigatebirds because they rely upon the large subsurface predators to push the species on 

which they feed to the surface (Orta 1992b). 

Breeding takes place on small, remote tropical islands. Nests and stick platforms are constructed on 

trees and bushes (e.g., Pisonia and Tournefortia bushes and trees on Rose Island), but when suitable 

vegetation is not available birds nest on bare ground (Orta 1992b). Lesser frigatebirds are sexually 

dimorphic; females tend to be heavier than males and males have a scarlet gular pouch that is inflated 

during courtship displays (Orta 1992b). They are seasonally monogamous; it is unlikely that pairs 

remain together for future breeding attempts (Orta 1992b). If successful, females can only breed 

successfully every 2–3 years since post-fledging care is provided by the female and can last 4–6+ 

months (Orta 1992b). Age to sexual maturity is unknown (Orta 1992b) but probably similar to that of 

great frigatebird at 8–10 years. 

Lesser frigatebirds feed in pelagic waters, usually in mixed-species flocks over tuna schools (Orta 

1992b, King 1967). Their diet consists primarily of flying fish and squid that they capture at or above 

the water’s surface (Nelson 1976). Lesser frigatebirds are also notorious for kleptoparasitism but 

obtain most of their food by direct capture (Nelson 1976). 

4.5.4 Fua’o (Sula dactylatra) or Masked Booby

Masked boobies have a pantropical distribution (Anderson 1993, Woodward 1972). There are four 

subspecies; S. d. personata breeds on islands in the central and western Pacific (Clements 2000). 

Within the USPI, the largest colonies are on Howland, Baker, and Jarvis Islands, but a significant 

portion of the population nests in the Northwestern Hawaiian Islands. Birds forage in offshore and 

pelagic waters (King 1967). They are most abundant in the vicinity of breeding islands, but they can 

be encountered far out at sea (King 1967). During nonbreeding periods, adults may visit sites 622–

1,243 miles from breeding colonies (Woodward 1972, Clapp and Wirtz 1975, O’Brien and Davies 

1990). 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 4. Biological Environment 4-25

The world population is widely distributed and therefore difficult to estimate but is thought to be 

several hundred thousand birds (Anderson 1993). Within the USPI, there are approximately 8,300 

breeding pairs with 1,200 pairs on Jarvis Island and over 1,500 pairs each on Howland and Baker 

Islands (Forsell 2002). Small colonies occur in American Samoa and Palmyra Atoll (Woodward 

1972, King 1967, Anderson et al. 1982), and Wake Atoll was recently recolonized by birds banded at 

Johnston Atoll (Rauzon et al. 2011). Rose Atoll is home to approximately 25 pairs. 

Masked boobies breed on oceanic islands and atolls. They tend to nest on open ground often near a 

cliff edge or on low sandy beaches or rocky ground (Anderson 1993, Harrison 1990). At Rose Atoll, 

they nest in open areas on the ground. They also form “clubs” or aggregations of nonbreeding birds 

on the fringe of breeding colonies (Woodward 1972). Breeding is fairly synchronous but timing 

varies depending on locality (Harrison 1990). Masked boobies are seasonally monogamous and at 

least 45% of pairs at Kure Atoll retained their mates through a second breeding season (Kepler 

1969). Two eggs are laid but broods are typically reduced to one chick by siblicide (Anderson 1993). 

Sexual maturity begins around 3–4 years and most birds return to their natal colony to breed 

(Anderson 1993, Nelson 1978, Kepler 1969). Adults sometimes skip a year between breeding 

attempts (Woodward 1972, Harrison 1990). 

Masked boobies feed by plunge-diving and can be found more than 93 miles from land (Harrison 

1990). They forage singly or in mixed-species flocks associated with schooling tuna (King 1967, 

Harrison et al. 1983). In Hawai‘i, fish constituted greater than 97% of the diet and squid less than 

3%; flying fish and jacks were the most important 

prey (Harrison et al. 1983). The oldest-known bird 

was 25 years. On Kure Atoll, annual adult mortality 

was less than 8.6%; mortality between independence 

and age 4 was 72% (Harrison et al. 1983). 

Masked boobies breed on a few islands with human 

populations but they are vulnerable to human 

disturbance (Anderson 1993). Depletion of tuna due 

to fishing could potentially have an impact on the 

availability of prey (Harrison 1990). Commercial-size 

mackerel scad were important in the diet of masked 

boobies at some locations, and potential effects of 

commercial fisheries are unknown (Harrison 1990). 

4.5.5 Fua’o (Sula leucogaster) or Brown Booby

Fua’o have a pantropical distribution (Schreiber and Norton 2002). There are four subspecies; S. l. 

plotus breeds on islands in the central and western Pacific (Clements 2000). In the USPI, brown 

boobies occur in the greatest numbers in the Hawaiian Islands. Breeding adults are mostly sedentary 

and juveniles disperse throughout the tropical seas (Carboneras 1992, Harrison 1990). At sea, they 

occur more nearshore than the other booby species (Sula dactylatra) and they are rarely seen over 50 

miles from the nearest land (King 1967). Little is known of movements during nonbreeding periods 

but adults have been found up to 1,802 miles from breeding sites (Schreiber and Norton 2002). 

Worldwide, the number of brown boobies is estimated at 221,000–275,000 pairs, which includes 

50,000–70,000 pairs of S. l. plotus (Schreiber and Norton 2002). About 3,700 pairs nest in the USPI; 

approximately 700 nest in American Samoa. At Rose there are approximately 375 breeding pairs of 

Fua’o chick testing its wings. Jiny Kim/USFWS
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

4-26 Chapter 4. Biological Environment

brown boobies. The world population has declined dramatically over the past 200 years and possibly 

only 1–10% of historic populations remain (Schreiber and Norton 2002). Currently the USPI 

population appears stable, with populations on Wake Atoll and Howland and Baker Islands gradually 

rebounding following eradication or control of cats (Rauzon et al. 2011). 

Fua’o breeding range overlaps with that of the other two species of booby on oceanic islands and 

atolls (Carboneras 1992, Harrison 1990). Nesting occurs on flat ground, often on cliff ledges, but 

they will also nest on sandy islands and bare coral atolls (Schreiber and Norton 2002). At Rose Atoll, 

brown boobies nest on the ground under the canopy of Pisonia and Tournefortia trees. Nests vary 

from a scrape in the sand to a fairly well-formed pile of twigs and grasses. Breeding is synchronous 

but timing varies depending on locality and occurs throughout the year (Schreiber and Norton 2002). 

Brown boobies are monogamous but maintenance of long-term pair bonds varies by location 

(Schreiber and Norton 2002). Pairs lay two (vary rarely three) eggs but the brood is often reduced to 

one chick as a result of siblicide (Schreiber and Norton 2002). Age of first breeding is typically 4–5 

years (Schreiber and Norton 2002, Harrison 1990). 

Fua’o feed by plunge-diving and feeding is often solitary, but they may be found in feeding flocks 

with other species (Schreiber and Norton 2002, Harrison 1990). They forage in nearshore waters, 

ranging from 5 to 44 miles from land, and feed mostly on flying fish, squid, mackerel scad, juvenile 

goatfish, and anchovy (Harrison 1990, Harrison et al. 1983). The oldest-known bird was 26 years, 

but they probably live to at least 30 years (Schreiber and Norton 2002, Simmons 1967). Adult 

survivorship was 93.2% at Kure Atoll 

(Tershey 1998). At Johnston Atoll, survival 

from fledging to breeding ranged from 30 to 

40% in an 18-year study (Schreiber and 

Norton 2002). 

A major threat to fua’o has been the loss of 

habitat to development and human 

disturbance; newer pairs are especially 

vulnerable at the beginning of the breeding 

season (Schreiber and Norton 2002). In 

American Samoa, hunting pressure on brown 

boobies was high during historic times and 

this may still occur on occasion (Amerson et 

al. 1982). 

4.5.6 Fua’o (Sula sula) or Red-footed Booby 

Red-footed boobies have a pantropical distribution that overlaps other booby species (S. dactylatra

and S. leucogaster) (Schreiber et al. 1996, Carboneras 1992). There are three subspecies; S. s. 

rubripes breeds in the central and western Pacific (Clements 2000). Red-footed boobies nest 

throughout the USPI. Distribution is pelagic; feeding flocks occur hundreds of miles from land 

(Harrison 1990). Breeding adults are mostly sedentary but juveniles roost near colonies on islands 

other than their natal island (Schreiber et al. 1996, Harrison 1990). Little is known about adult 

movements outside of the nesting season (Schreiber et al. 1996). 

The world population was estimated at less than 300,000 pairs in 1996 (Schreiber et al. 1996). In the 

USPI, there are approximately 19,000 pairs. Approximately 2,000 pairs nest in American Samoa 

Brown and red-footed boobies. USFWS
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 4. Biological Environment 4-27

Nesting gogo uli. USFWS

(Amerson et al. 1982). Rose Atoll hosts 700 pairs of this species. The world population has been 

severely reduced over the last two centuries (Schreiber et al. 1996) and few data exist on current 

numbers (Cao et al. 2005). Cao et al. (2005) suggest the present day population size has declined to 

10% of their historical values. 

This species of booby is the smallest of the booby species and breeds on oceanic islands and atolls 

(Schreiber et al. 1996, Carboneras 1992). Unlike the masked and brown boobies, these boobies roost 

and nest on shrubs and trees but will use bare ground or low piles of vegetation (Schreiber et al. 

1996, Carboneras 1992, Harrison 1990). On Rose Island, red-footed boobies build nests in 

Tournefortia and Pisonia trees. Nests are made of twigs, grass, and other vegetation. Breeding is 

fairly synchronous but occurs throughout the year and timing varies by locality (Schreiber et al. 

1996, Harrison 1990). Several color phases exist, ranging from all brown to all white (Schreiber et al. 

1996, Nelson 1978). The most common color morph at Rose is the intermediate form. They are 

monogamous and generally retain their mates throughout subsequent breeding seasons (Schreiber et 

al. 1996). They lay 1 egg and continue to feed the young 1–2 months after fledging (Schreiber et al. 

1996, Carboneras 1992). Sexual maturity begins around 3–4 years and most birds return to their natal 

colony to breed (Schreiber et al. 1996, Harrison 1990). Adults usually breed every year but 

sometimes take a “rest” year (Schreiber et al. 1996, Harrison 1990). 

Red-footed boobies feed on flying fish, squid, mackerel scads, saury, and anchovies (Harrison 1990). 

Red-footed boobies often depart the colony to feed well before daylight and most return to the colony 

to roost at night (Carboneras 1992, Harrison 1990). Red-footed boobies feed by plunge-diving and 

may feed solitarily or in mixed-species foraging flocks (Au and Pitman 1986). They forage further 

from land than other boobies except possibly the masked booby (Nelson 1978). Annual adult survival 

was estimated at 90% in a 2-year study at French Frigate Shoals in the NWHI (Hu 1991). At 

Johnston Atoll, survival of chicks to breeding ranged from 27 to 52% depending on the year 

(Schreiber et al. 1996). The oldest-known bird was 22 years (Clapp et al. 1982). 

The large areas of mangrove forests destroyed in American Samoa may have once been important 

habitat for this species. Introduced scale insects and other factors at Rose Island are destroying the 

Pisonia forest. Human predation on adults, chicks, and eggs may occur in parts of American Samoa 

(Amerson et al. 1982). El Niño-Southern Oscillation conditions can cause total or partial breeding 

failure in some locations (Schreiber and Schreiber 1989, Schreiber 1994). 

4.5.7 Gogo Uli (Anous minutus) or Black Noddy

The gogo uli is an abundant and gregarious, 

medium-sized bird with a pantropical 

distribution (Gauger 1999, Clements 2000). 

Adults are sooty black with a white cap on the 

top of the head. There are seven recognized 

subspecies and at least three breed in the USPI: 

A. m. melanogenys in the main Hawaiian Islands; 

A. m. marcusi in the NWHI, Wake, and 

throughout Micronesia; and A. m. minutus in 

Samoa (Gauger 1999, Gochfeld and Burger 

1996). Breeding adults are mostly sedentary 

remaining at colonies year-round and foraging 

within approximately 50 miles of nesting islands 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

4-28 Chapter 4. Biological Environment

Nesting gogo. USFWS

(Gauger 1999, Ashmole and Ashmole 1967, King 1967). Juveniles probably remain at breeding 

colonies or travel to nearby roosting sites (Gauger 1999). 

The world population is estimated to be 1,000,000–1,500,000 pairs (Gauger 1999). In the USPI, there 

are approximately 22,400 pairs. An estimated 12,000 pairs nest in the Hawaiian Islands, and smaller 

colonies exist in American Samoa, Palmyra, Johnston, and Wake Atolls, and the Marianas.

Approximately 750 pairs use Rose Atoll. Worldwide population trends are unknown. 

The gogo uli nest on oceanic and offshore islands (Gauger 1999). They place their nests on trees and 

bushes (Howard and Moore 1984, Harrison 1990); the nests on Rose Island are in Tournefortia 

branches. Breeding is asynchronous and aseasonal. Birds are monogamous, mate retention is high, 

and pairs retain their territory from year to year, often reusing the same nest (Gauger 1999, Schreiber 

and Ashmole 1970). The gogo uli are capable of producing more than one brood per year and some 

lay a second egg while still tending the first chick (Gauger 1999). Sexual maturity begins around 2–3 

years (Gauger 1999). The oldest-known bird was 25 years (Gauger 1999). 

Black noddies feed by hover-dipping and contact-dipping, and typically forage in multi-species 

flocks over schools of predatory fish, especially tunas and jacks (Ashmole and Ashmole 1967). They 

feed mainly inshore (<6 miles from shore) and sometimes within several feet of the shoreline 

(Harrison 1990, Gauger 1999). Black noddies eat fish almost exclusively and very small amounts of 

squid and crustaceans (Gauger 1999). In the central Pacific, flying fish, blennies, mackerel, and 

anchovies are important components of the diet (Gauger 1999). 

Predation by introduced mammals in the breeding colonies limits populations and depletion of large 

predatory fish density due to fishing may reduce feeding opportunities (Gauger 1999). 

4.5.8 Gogo (Anous stolidus) or Brown Noddy

The brown noddy is a medium-sized tern with a pantropical distribution (Chardine and Morris 1996), 

dark brown in color all over except for the whitish-gray cap on the top of its head. There are five 

subspecies; A. s. pileatus breed in the central and western Pacific (Harrison and Stoneburner 1981). 

Brown noddies have been shown to breed more than once per year in the NWHI (Megyesi and 

Griffin 1996). Breeding adults remain within sight of the colony, foraging in waters several tens-ofmiles from the colony (Morris and Chardine 1992, Clements 2000). During nonbreeding periods, 

brown noddy have been shown to stay within 62 miles of colonies (Clapp et al. 1983, Harrison 1990) 

or to migrate out of the area for several 

months (Murphy 1936, Morris and Chardine 

1992). Little is known of the movements of 

juveniles (Chardine and Morris 1996). 

The world population is estimated at 

500,000–1,000,000 pairs (Chardine and 

Morris 1996). Within the USPI, there are 

about 135,000 pairs (Harrison et al. 1983). 

Approximately 9,000–11,000 pairs nest in 

American Samoa, the Marianas, and 

Johnston Atoll (Amerson et al. 1982, Reichel 

1991). Approximately 200 pairs nest at Rose 

Atoll. The population trend is probably 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 4. Biological Environment 4-29

Nesting manu sina with egg on Tournefortia branch. 

USFWS

stable, but increasing in areas where predators were removed (e.g., Midway, Kure) (Chardine and 

Morris 1996). 

Brown noddies usually nest in loose groups or colonies and are flexible in nesting behavior. Nests are 

on the ground, often on open slopes or under vegetation but the brown noddy also nest on cliffs and 

in trees, especially where introduced mammalian predators are present (Harrison 1990, USFWS 

1983). Brown noddy pairs stay together throughout the year, but there is little information on mate 

retention in subsequent years (Chardine and Morris 1996). Sexual maturity begins around 3–7 years 

and it is unknown whether birds return to their natal colony to breed (Chardine and Morris 1996, 

Harrison 1990). The oldest-known bird was 25 years (Chardine and Morris 1996). 

Brown noddies feed by hover and contact-dipping in nearshore and off-shore waters (Harrison et al. 

1983). They often feed in association with tuna schools and can be found in mixed-species feeding 

flocks. 

The greatest threat is introduced predators, and where there are predators, brown noddy often nest in 

trees (Chardine and Morris 1996, Harrison et al. 1983). Predation by introduced mammals, such as 

the Polynesian rat, has contributed to the extirpation of brown noddy from islands where they 

formerly nested (e.g., Lehua) (VanderWerf et al. 2004). Disturbance of the colonies can lead to 

increased predation by native predators: unprotected eggs are taken by atafa and shorebirds, 

especially when adults are flushed from nests by human disturbance. 

4.5.9 Manu Sina (Gygis alba) or White Tern

The manu sina is small and entirely white, 

with a pantropical distribution (Niethammer 

and Patrick 1998, Gochfeld and Burger 1996). 

The manu sina has adapted well to humanaltered landscapes better than many other 

seabirds. It is perhaps the most familiar bird in 

Samoa (Craig 2002). There are four 

subspecies; G. a. alba breed in the central and 

western Pacific (Gochfeld and Burger 1996, 

Clements 2000). Breeding adults remain close 

to colonies, foraging primarily inshore in 

shoals and banks but sometimes in offshore 

waters (Niethammer and Patrick 1998). 

During nonbreeding periods they disperse 

from breeding grounds to sea but their range is unknown (Niethammer and Patrick 1998). Some 

adults are year-round residents on the colony (Harrison 1990). Little is known of the movements of

immature manu sina. 

World population is unknown but probably exceeds 100,000 pairs (Gochfeld and Burger 1996). In 

the USPI, there are about 17,000 pairs. Large colonies exist in American Samoa (3,900 pairs) 

(Amerson et al. 1982). Rose Atoll supports at least 60 pairs. World and USPI population trends are 

unknown. 

Manu sina nest on volcanic pinnacles, cliffs, rocky slopes, in large bushes or trees, or on artificial 

substrates (Niethammer and Patrick 1998, Rauzon and Kenyon 1984). They do not build nests but lay 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

4-30 Chapter 4. Biological Environment

a single egg on a suitable depression, sometimes precariously balancing on small tree branches.

Manu sina are monomorphic and monogamous, and partners remain together for several seasons, 

often returning to the same nest site (Niethammer and Patrick 1998, Harrison 1990). Clutch size is 

one egg and some breeding pairs may successfully raise two or even three broods within a nesting 

season (Niethammer and Patrick 1998, VanderWerf 2003, Miles 1985). 

Manu sina feed primarily by dipping- and surface-diving (Niethammer and Patrick 1998). They often 

occur in mixed feeding flocks and usually in association with predatory fish (Niethammer and 

Patrick 1998, Harrison 1990). Prey items include juvenile goatfish, flying fish, squid, needlefishes, 

halfbeaks, dolphinfishes, and blennies (Niethammer and Patrick 1998, Harrison et al. 1983). 

Although manu sina exhibit lower vulnerability to introduced predators than most seabirds because 

of their ability to use inaccessible (e.g., trees and sheer cliffs) nesting sites, introduced predators such 

as rats and cats have been the primary factor affecting populations (Niethammer and Patrick 1998). 

Scale insects have been introduced to Kure, Rose, and Palmyra Atolls where they attack native 

vegetation and reduce the number of nest sites in the native forest; the effects on manu sina nesting 

populations are not known. Depletion from fishing of large predatory fish stocks that drive prey to 

the surface may reduce foraging opportunities for manu sina (Niethammer and Patrick 1998, 

Gochfeld and Burger 1996). 

4.5.10 Gogosina (Onychoprion fuscatus) or Sooty Tern

Sooty terns have a pantropical distribution (Gochfeld and Burger 1996, Clements 2000, Schreiber et 

al. 2002). There are eight subspecies; O. f. oahuensis breed in the central and south Pacific (Gochfeld 

and Burger 1996, Clements 2000). Breeding adults remain relatively close to colonies and forage up 

to 311 miles from breeding islands (Flint 1991, Gould 1974). During nonbreeding periods, they are 

highly pelagic and tend to avoid regions with cold-water upwelling (Gochfeld and Burger 1996, 

Schreiber et al. 2002). Juveniles disperse widely after fledging and remain at sea, sometimes not 

touching land for several years (Schreiber et al. 2002). 

The world population is estimated to range from 60 to 80 million pairs with 18–23 million pairs 

breeding each year (Schreiber et al. 2002). In the USPI, there are approximately 3.2 million pairs. A 

large colony of more than 100,000 pairs breeds at Rose Atoll (Amerson et al. 1982). Sooty tern nest 

on oceanic islands and atolls in large dense colonies (Gochfeld and Burger 1996, Schreiber et al. 

2002). A colony usually consists of several subcolonies and each subcolony breeds very 

synchronously. Sooty tern nest on the ground in sandy substrate with sparse vegetation (Schreiber et 

al. 2002). On Rose Island sooty terns also move into 

the forest and lay eggs in the open understory there. 

Sexual maturity begins around age 4–10 years 

(Schreiber et al. 2002, Harrington 1974). The 

oldest-known bird was 32 years (Harrison 1990). 

Sooty terns, the most pelagic of the tropical terns 

(King 1967), feed mainly by aerial-dipping, contactdipping, and aerial capture, although they will 

plunge-dive (Gochfeld and Burger 1996, Schreiber 

et al. 2002). Sooty terns tend to feed in large flocks 

with other species in association with predatory 

fishes, such as yellowfin and skipjack tunas 

Gogosina. Jiny Kim/USFWS
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 4. Biological Environment 4-31

(Schreiber et al. 2002, Harrison 1990, USFWS 1983). El-Niño-Southern Oscillation conditions can 

cause breeding failure in the Pacific (Schreiber and Schreiber 1989). 

Native predators such as atafa and tuli take chicks and eggs (Schreiber et al. 2002, Harrison 1990). 

Sooty terns are vulnerable to oil pollution from tankers and spills. Depletion of tuna by fisheries 

could potentially have an impact on the availability of prey (Schreiber et al. 2002). 

4.5.11 Gogosina (Onychoprion lunatus) or Gray-backed Tern 

Gray-backed terns are endemic to the tropical and subtropical Pacific but are most common in the 

Central Pacific (Mostello et al. 2000, Harrison 1990). Breeding adults are mostly sedentary and 

forage up to 230 miles from land (Harrison 1990, Dixon and Starrett 1952). During nonbreeding 

periods, they are highly pelagic and occur far from breeding colonies, but their range is unknown 

(Mostello et al. 2000). At sea, gray-backed terns are found in highly saline waters (Ainley and 

Boekelheide 1983). There are limited data on movements, but juveniles travel great distances after 

leaving the natal colony (Mostello et al. 2000). 

The world population size is unknown but possibly on the order of 70,000 pairs (Mostello et al. 

2000). Lack of adequate information on breeding phenology in many areas complicates estimates 

(Mostello et al. 2000). In the USPI there are approximately 48,000 pairs and 30 pairs nesting on Sand 

Island at Rose Atoll. The global population trend is difficult to assess, but probably has declined 

since some colonies have been extirpated (Mostello et al. 2000). In the USPI, the population appears 

stable or increasing, but historical declines occurred at remote Pacific islands due to introduced 

predators. Trends in the USPI may be increasing with the removal of predators such as cats from 

many islands and places such as Howland, Jarvis, and Wake Atoll (Rauzon et al. 2011). 

Gray-backed terns breed on remote islands and atolls, on rocky ledges or sandy beaches often along 

vegetated edges bordering open areas (Amerson 1971, Ely and Clapp 1973). Their nests are shallow 

depressions in sand or gravel. Breeding occurs throughout the year. The clutch is one egg and chicks 

are semi-precocial when hatched (Mostello et al. 2000). Fledglings may remain at the colony up to 6 

weeks after first flight (Harrison 1990). The oldest-known gray-backed tern was 25 years (Mostello 

et al. 2000). 

Gray-backed terns feed mainly by plunge-diving or contact/hover-dipping. They are described as an 

inshore, offshore, or pelagic feeder due to the geographical and seasonal differences in foraging 

habitat (Mostello et al. 2000). Gray-backed terns eat five-horned cowfish, juvenile flying fish, 

goatfish, herring, dolphinfish, squid, crustaceans, mollusks, and marine and terrestrial insects 

(Harrison 1990). Gray-backed terns can be found foraging in mixed-species flocks, especially with 

sooty terns and sometimes with ta’i’o (Gould 1971). 

In the USPI, their gravest threat is predation by introduced mammals such as rats and cats (Harrison 

1990, Woodward 1972, Harrison et al. 1983). They are sensitive to disturbance, leaving their eggs 

when humans approach (Harrison 1990). Unattended eggs and chicks are vulnerable to predators 

such as atafa and ruddy turnstones and curlews (Mostello et al. 2000). Gray-backed terns tend to nest 

near the surf zone and nests are often lost to storm tides (Mostello et al. 2000, Harrison 1990). 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

4-32 Chapter 4. Biological Environment

Gogosina (black-naped tern) in flight.

Joshua Fisher/USFWS

4.5.12 Gogosina (Sterna sumatrana) or Black-naped Tern

The black-naped tern is a white, small-sized bird 

with grayish-white back and wings and black beak 

and legs. This species has only recently (2010) been 

observed at Sand Island when a single adult 

individual was seen acting as if it might have a nest 

territory. No egg or chick was found. They breed on 

tropical and subtropical islands throughout the Indian 

and western Pacific Oceans. Breeding takes place on 

small offshore islands, reeds, sand spits, and rocky 

cays (Bird Life International 2011). Breeding season 

depends on locality (Bird Life International 2011) 

but have been recorded at breeding stations 

throughout the year, suggesting mainly sedentary 

habits (Harrison 1985). Colonies of 5–20 pairs are 

formed, but sometimes up to 200 pairs can be formed (Bird Life International 2011). Colonies tend to 

be linear, or parallel to the water’s edge, (Hulsman and Smith 1988) in the sand or gravel pockets on 

coral banks close to the high tide line and monospecific (del Hoyo et al. 1996). They are also known 

to form colonies on shipwrecks (Hulsman and Smith 1988). One to two eggs, but occasionally three, 

are laid in either a shallow scrape on open ground or no nest is made (Hulsman and Smith 1988). 

Hulsman and Smith (1988) found that pebbles and small debris were thrown up toward the nest, 

having the effect of building up the nest edge, during nesting relief ceremonies. 

Black-naped terns hunt singly or in loose groups (Hulsman 1979) in atoll lagoons and nearshore, but 

they occasionally join flocks of black noddies when predatory fish are active near the reef (Hulsman 

and Smith 1988). Black-naped terns feed predominantly by plunging or air diving directly onto prey 

(Hulsman and Smith 1988, Bird Life International 2011), but become only semi-submerged 

(Harrison 1985). 

Both parents feed their young and make frequent flights to hunting grounds and young. Hulsman 

(1979) found anchovy to be a main food source for adults, but adults also consumed flying fish, 

mullet, barracuda, trevally or jack, tuna, damselfish, sardines, dolphinfish, grubfish, goby, blennies, 

and wrasse. Chicks were fed principally on the silver schooling fish belonging to the hardyheads and 

sprats, anchovies, and garfish. 

Black-naped terns are sensitive to human disturbance, either in terms of reduced breeding success or 

colony desertion. Black-naped terns nest in the open, which exposes their eggs and young to the 

weather. Adults must, therefore, shelter their eggs and chicks from the wide range of weather 

conditions experienced in tropical and sub-tropical areas. On two islands in Australia, the major 

causes of mortality of eggs and chicks were predation by gulls and flooding of nesting areas 

(Hulsman and Smith 1988), indicating that any introduced predators or excessive human disturbance 

would cause birds to flush, rendering chicks vulnerable to nonnative predators as well as native birds 

like tuli or atafa.
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 4. Biological Environment 4-33

4.6 Shorebirds and Wading Birds

The Pacific Island Region functions as an essential migratory habitat for maintaining global 

shorebird populations. Rose Atoll is an important wintering ground for shorebirds in the Pacific. 

Seven species have been recorded at Rose Atoll. The most common migratory shorebirds are the 

Pacific golden plover, ruddy turnstone, and wandering tattler. Some shorebirds primarily use the 

beach strand habitat; however, the littoral forest also serves as important habitat. The Pacific golden 

plover is the most abundant of the shorebird species in American Samoa (Engilis and Naughton 

2004) and also the species that has been seen in largest numbers at Rose Atoll. 

Information on the status, trends, and ecology of shorebirds in the Pacific and their use of Rose Atoll 

is lacking in published literature (Engilis and Naughton 2004). Information 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 (Engilis and Naughton 2004). 

Many shorebirds wintering in the Pacific migrate over 2,486–7,458 miles of open ocean. Based on 

banding recoveries, patterns of distribution, and species assemblages, the following three flyways 

have been proposed: Asiatic-Palauan Flyway (birds move from Asia to Western Pacific and 

Philippine Sea Islands), Japanese-Mariana Flyway (mostly Asian birds move through Japan into the 

Mariana Islands and Caroline Islands), Nearctic-Hawaiian Flyway (birds breeding in Alaska and 

Eastern Siberia [Beringia] move through Hawai‘i to Marshalls and Polynesia) (Baker 1953). 

The Service developed the USPI Regional Shorebird Conservation Plan (Engilis and Naughton 2004) 

over concerns of declining shorebird populations and loss of habitat. Threats to shorebirds in the 

Pacific region include loss of habitat, nonnative plants, nonnative animals (predation, disease, and 

competition), human disturbance, and environmental contaminants. 

Conservation and restoration of shorebird habitats in the USPI is a growing effort and 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 limited acreage. 

Table 4-3. Shorebirds and Wading Birds of Primary Conservation Importance in the U.S. 

Pacific Region 

Species Regional Trend Conservation category 

Pacific golden plover Unknown High concern

Bristle-thighed curlew Unknown High concern

Sanderling Unknown High concern (?)

Wandering tattler Unknown Moderate concern

Ruddy turnstone Unknown Low concern

Pacific reef heron Unknown IUCN Least Concern

Source: Engilis and Naughton 2004; USFWS 2008.
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

4-34 Chapter 4. Biological Environment

4.6.1 Tuli (Arenaria interpres) or Ruddy Turnstone

The ruddy turnstone is a common shorebird throughout the Pacific Islands; however, it is recognized 

as a species of Low Concern (Engilis and Naughton 2004) because the vast majority of its world 

population uses other areas for wintering grounds. Remote sandy islands appear to support the largest 

numbers of turnstones in the USPI, but there are no available survey estimates for the wintering 

population at American Samoa (Engilis and Naughton 2004). The largest group ever recorded at 

Rose Atoll was 45 in 1982. Ruddy turnstones use sandy and rocky beaches, reefs, and mudflats. 

4.6.2 Tuli (Calidris alba) or Sanderling 

The sanderling is widespread and locally common throughout the Pacific Islands. In the USPI, the 

sanderling is less often seen than wandering tattlers and tuli. The USPI Regional Shorebird 

Conservation Plan (Engilis and Naughton 2004) designated this shorebird as a species of limited 

importance in the Pacific Islands since the vast majority of sanderlings overwinter in other regions of 

the world. They are usually found on the water’s edge in small groups where they run back and forth 

from the waves to feed on the small invertebrates exposed by the retreating waves. 

4.6.3 Tuli (Tringa incana) or Wandering Tattler

The wandering tattler is nowhere common but is ubiquitous throughout the Pacific region. 

Predominantly nearctic breeders, wandering tattlers migrate from their breeding grounds in Alaska

and northwest Canada (Gill et al. 2002) to islands throughout the Pacific. During winter, they are 

solitary or occur in small groups of two to three birds throughout the Pacific Basin (Gill et al. 2002). 

They are most common on rocky beaches but they also use a wide range of habitats including 

exposed reefs, sandy beaches, and mudflats (Engilis and Naughton 2004, Gill et al. 2002). The USPI

Regional Shorebird Conservation Plan (Engilis and Naughton 2004) estimated the total population of 

wandering tattlers between 10,000 and 25,000 individuals. There are an estimated 900 wandering 

tattlers wintering in American Samoa (Amerson et al. 1982). 

4.6.4 Matu’u (Egretta sacra) or Pacific Reef Heron 

The matu’u is a common bird in Samoa, with long legs and a long neck that is often curved in an Sshape. There are three color morphs: dark gray, pure white, or a combination of both colors in 

patches, and all have been observed at Rose Atoll. The herons forage across the reef crest for a wide 

variety of reef fish, crabs, and snails, as well as freshwater streams for food. Matu’u construct their 

large nests in trees that are safe from predators. At Rose Island nests have been found in niu and 

Cordia surrounded by thick ferns (Nephrolepis hirsutula). In the 2010 field visit to Rose Atoll, there 

were two nests, one with two chicks and one with one chick. The white and dark color morphs were 

both seen on this visit. Population numbers in American Samoa are not known. 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 4. Biological Environment 4-35

4.7 Land Birds

Rose serves as nonbreeding habitat for one austral migrant, the long-tailed cuckoo or aleva 

(Eudynamis taitensis). Vagrant birds are those that occasionally are blown off course by storms or by 

faulty directional decision during migration. Three vagrant species have been sighted at Rose Atoll: 

the cattle egret (Bubulcus ibis), snowy egret (Egretta thula), and the wattled honeyeater (Foulehaio 

carunculata). 

4.7.1 Aleva (Eudynamis taitensis) or Long-tailed Cuckoo

The aleva migrates from New Zealand in the winter and forages toward the southwest Pacific. The 

center of its winter range lies in central Polynesia (Kepler et al. 1994). On Rose Island, its habitat is 

in dense and thick cover of the littoral forest. Single birds have been sighted 1976, 1980, 1990, and 

1992. Two were observed in 1984. The very cryptic and stealthy behavior of this species makes it 

likely that it is more common than field observations would indicate and on some visits the bird is 

heard but not seen as in 2010. 

4.8 Invertebrates 

4.8.1 Tuitui (Sea Urchin)

Tuitui are marine animals that belong to the phylum Echinodermata (meaning “spiny skin”), a group 

that includes sea stars (also called starfish), sea cucumbers, sand dollars, brittle stars, and sea 

feathers. All tuitui are in the Class Echinoidea. Sea urchins are important herbivores in reef and other 

marine habitats, grazing on a variety of benthic algae. An urchin’s mouth lies on the undersurface of 

its hard shell; the jaws of the mouth are made from five teeth held in a muscular sling. Together these 

teeth form a five-pointed beak that is very effective at scraping algae from rocks and other hard 

surfaces. The scraping jaws of rock-boring urchins are also used to enlarge natural cavities or holes 

in the hard substrate, providing the animal with shelter from the full force of waves on exposed reef 

flats and the wave-swept surge zone. 

Tuitui feeding has two important consequences. 

First, their grazing reduces the total amount of fleshy 

algae on a reef, which enables corals and CCA 

(which compete with algae and cyanobacteria for 

space and sunlight) to grow better. Second, when 

they scrape algae from the substrate, they create 

vacant spaces that can then be colonized by the 

larvae of other bottom-dwelling marine animals. This 

helps to keep the diversity of marine animals high. In 

the absence of such grazing, reefs may become 

overgrown with algae, and the diversity of reef 

animals may be reduced. The important ecological 

role of tuitui became apparent on Caribbean reefs 

after a disease outbreak in 1983–84 killed more than 

Tuitui. Jean Kenyon/USFWS
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

4-36 Chapter 4. Biological Environment

93% of the long-spined urchins (Diadema antillarum). During the following years, coral abundance 

decreased and reefs were covered with unprecedented levels of algal growth. 

Tuitui in the genera Heterocentrotus, Diadema, Echinometra, Echinothrix, and Echinostrephus have 

been recorded from Rose Atoll (Swerdloff and Needham 1970, Green et al. 1997, NMFS PIFSC 

2008). Following the longliner grounding in 1993, biologists documented an extensive area where oil 

caused high mortality to tuitui as well as CCA, marine snails, and faisua. Surveys in 1993 revealed 

that boring tuitui were extirpated from a zone 295 feet north and 197 feet south of the spill site 

(Molina 1994, Green et al. 1997). Surveys conducted in 1995 and 1996 revealed that tuitui densities 

had declined along the atoll’s entire southwest arm (Green et al. 1997). As of 1997, the tuitui 

population continued to be reduced within 3,279 feet of the grounding site, and remained depressed 

as of 2001 (USFWS and DMWR 2001). With the clean-up of the shipwreck completed, the area is 

recovering, and it is likely that tuitui numbers are rebounding as well. 

4.8.2 Terrestrial Invertebrates

With the exception of scale insect documentation 

in reports from 2002 to 2005, few observations of 

terrestrial invertebrates were reported by visitors to 

Rose Atoll. In his 1980 trip report, Shallenberger 

notes that Darrell Herbst collected “various 

insects” while on Rose and Sand Islands. 

Shallenberger also states that the strawberry hermit 

crab (Coenobita perlatus) gather under the T. 

argentea during the day, and forage across the 

island at night. Strawberry hermit crabs were 

observed foraging on dead birds, fish, coconut 

meat, and bird eggs (Shallenberger 1980). Though found in smaller numbers than the strawberry 

hermit, purple hermits (Coenobita brevimanus) were also extremely common until the mid-90s when 

densities of both hermit species appeared to decline. 

With the coincident decline in overall numbers came a change in the quality of the gastropod shells 

these crabs were using. It became more common to see highly worn shells and a lower proportion of 

the favored Turbo shells in the population. The largest terrestrial arthropod on earth, the coconut crab 

(Birgus latro), ranges throughout the tropical Indo-Pacific. Due to its popularity as a food source, 

coconut crabs are rare or absent on most inhabited islands (Kepler and Kepler 1994). A single small

coconut crab was captured in a live trap set for rats in 1991. Possibly related to the elimination of rats 

and the subsequent increase in niu, two dens and a large adult Birgus was observed on Rose Island 

during the 2010 Refuge visit. Terrestrial invertebrates also observed on a Service trip to Rose Atoll 

led by Flint (Flint 1990) documented fruit flies, crickets, scales, wasps, houseflies, ants, earwigs, 

beetles, moths, cockroaches, orb-weaving spiders, wolf spiders, jumping spiders, and red spider 

mites. However, they were not collected or identified to species. 

In April 2012 a team of five entomologists from the U.S. Geological Survey, American Samoa 

Community College (ASCC), DMWR, and the Service spent 5 days surveying invertebrates on Rose 

Island. They set out a variety of traps in about 100-foot grids covering the island. The final report of 

their findings was not yet available at the time of this writing. 

Coconut crab. USFWS
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 4. Biological Environment 4-37

4.9 Reef Building Species

Coral reefs can be considered geologic structures built by countless generations of corals, coralline 

algae, and other calcifying marine organisms. While coral reefs are the world’s largest structures 

made by living organisms, an individual coral polyp is a tiny animal. What many people think of as a 

single coral is actually a colony of hundreds to 

thousands of tiny coral animals living side by 

side on a colonial skeleton they have excreted. 

Because many of these organisms are attached to 

the substrate, their skeletons remain in that 

position after they die. Loose pieces of coral, 

shells, and other hard building blocks can be 

cemented together by coralline algae to build the 

reef. New reef organisms settle on or grow over 

the remains of the previous generation and 

deposit their skeletal material over the older 

surface. By this process a wave-resistant reef 

builds upward and outward. 

Due to the critical symbiosis between stony 

corals and their photosynthetic zooxanthellae, reef construction requires warm, clear, well-lighted 

marine waters. Coral reefs are mostly found between 30o

N and 25oS latitude where the surface water 

temperature ranges between 77o

 and 86oF throughout the year. In deep water (164-328 feet), where 

much of the sunlight is filtered out, the number of reef-building species of corals is greatly reduced, 

and at deeper depths (greater than 328 feet) most reef builders disappear altogether. 

Atolls vary in the degree to which their annular reef encloses the central lagoon and are sometimes 

further described on a gradient of “open” to “classical” as the perimeter reef becomes more fully 

enclosing. An operational definition of a classical atoll, therefore, is a reef formation atop a subsiding 

extinct volcano that includes a lagoon surrounded by a shallow perimeter reef, at least one emergent 

island, and regular surface water exchange between the lagoon and the open ocean (Woodroffe and 

Biribo 2011, Maragos and Williams 2011). In this regard, Rose Atoll, despite its small size, meets 

this definition of a classical atoll and also has all the major habitats and associated biological groups 

found on Pacific atolls: 

• Perimeter (annular) reef enclosing the lagoon; 

• Reef crest (reef flat); 

• Back reef (slopes facing the lagoon); 

• Lagoon; 

• Lagoon reefs; 

• Islands; 

• Natural channel (ava); and

• Fore reef (slopes facing the ocean). 

4.9.1 Coral

Corals and reefs in many regions of the world are reported to be in a state of decline due to numerous 

local and global anthropogenic stressors including coastal point source pollution, agricultural and 

Each small bump on the branches of this coral colony 

(Acropora humilis) is a corallite that protects a softbodied polyp inside. Jean Kenyon/USFWS
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

4-38 Chapter 4. Biological Environment

land use practices, overuse for commercial or recreational purposes, disease and predation, and 

impacts of climate change including increased sea surface temperature and ocean acidification 

(Wilkinson 2004). While the reefs of Rose Atoll have been spared many of the anthropogenic threats 

and impacts that afflict reefs located closer to human population centers, some threats such as climate 

change are very widespread and challenge the ability of protected areas to limit their effects. Veron et 

al. (2009) state that “reefs are likely to be the first major planetary-scale ecosystem to collapse in the 

face of climate changes now in progress”.

Taxonomy. Stony corals are marine invertebrates in the phylum Cnidaria that secrete a calcium 

carbonate exoskeleton. The basic soft body form of a coral is called a polyp, consisting of a sac-like 

cavity with only one opening that serves as both mouth and anus. This opening is surrounded by 

tentacles that have stinging cells called nematocysts. The skeleton secreted by an individual polyp is 

called a corallite. Some corals are solitary, consisting of a single polyp and its corallite, but most are 

colonial, consisting of multiple interconnected polyps that developed by a process of budding from 

an original parent polyp. 

From a taxonomic perspective, stony corals include members of both the Class Hydrozoa (fire corals) 

and the Class Anthozoa, Order Scleractinia (true stony corals). From a functional perspective, corals 

that contain single-celled, endosymbiotic, photosynthetic algae known as zooxanthellae in their 

gastrodermal tissues are called hermatypic or reef-building corals. The rapid calcification rates of 

these corals have been linked to their mutualistic association with the zooxanthellae. 

One hundred forty-five stony corals (143 scleractinian and 2 hydrozoan) (Appendix A) have been 

reported from the Refuge and the adjoining fore reef slopes (Kenyon et al. 2010, 2011). Higher coral 

diversity than expected at Rose Atoll may result from its proximity to the high islands in American 

Samoa where 326 scleractinian species have been recorded (Birkeland et al. 2008) and from its 

additional lagoon habitats compared to those islands. 

Of these 145 stony coral species at Rose Atoll, 21 are listed as Vulnerable according to the IUCN

Red List Categories and Criteria. These criteria have been widely used to classify, in an objective 

framework, the extinction risk of a broad range of species and rely primarily on population size 

reduction and geographic range information. Categories used to classify species for which adequate 

data exist range from “Least Concern” (with very little probability of extinction) to high risk 

“Critically Endangered.” The categories collectively considered as “threatened” (Vulnerable, 

Endangered, Critically Endangered) are intended to serve as one means of setting priority measures 

for biodiversity conservation (Carpenter et al. 2008). Of these 21 species at Rose Atoll listed as 

Vulnerable, 19 were evaluated by NOAA NMFS

for possible listing in accordance with the ESA, in 

response to a petition in 2009 from the nongovernmental organization (NGO) Center for 

Biological Diversity (Kenyon et al. 2011). On 

November 30, 2012, NOAA found 12 of these 

species warranted listing as threatened and initiated 

a 90-day public comment period. Of the remaining 

124 stony coral species at Rose Atoll, 36 are listed 

by the IUCN as “Near Threatened,” 78 as “Least 

Concern,” 2 as “Data Deficient,” and 8 are not 

found in the Red List. The fore reef slope supports a diverse assemblage of corals, 

other invertebrates, and coralline algae. 

Jean Kenyon/USFWS
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 4. Biological Environment 4-39

For coral reef ecosystem species, Essential Fish Habitat (EFH) (MSFCMA; 16 U.S.C. 1855(b)) 

(§305(b)) has been designated as the water column above the reefs and all bottom out to 328 feet 

depth across all the USPI. Federal agencies which fund, permit, or undertake activities that may 

adversely affect EFH are required to consult with the NMFS regarding the potential effects of their 

actions on EFH. 

Zooxanthellae. In addition to enhancing calcification, zooxanthellae provide a substantial 

phototrophic contribution to the coral’s energy budget and give the coral most of its color. Those 

corals that lack zooxanthellae deposit mineralized skeletal materials at a lower rate and are called 

ahermatypic or nonreef-building corals. The largest colonial members of the Scleractinia help 

produce the carbonate structures known as coral reefs in shallow tropical and subtropical seas around 

the world. Stony corals with massive and branching growth forms are the major framework builders 

and a source of carbonate sediment on the reef. Corals provide substrate for colonization by other 

benthic organisms, construct complex protective habitats for a myriad of other species including 

commercially important invertebrates and fishes, and serve as food resources for a variety of animals.

Rose Atoll Coral Distribution. Coral cover and composition naturally vary among atoll habitats 

because species show differential growth and survivorship responses to different environmental 

circumstances including wave energy, depth and turbidity (light penetration), and temperature range 

tolerance. In 2002, average coral cover derived from quantitative analysis of imagery recorded during 

towed-diver surveys that circumnavigated the Rose Atoll fore reef in 3 depth strata was 23% 

(Kenyon et al. 2010); average coral cover was highest (38%) on the deep (greater than 59 feet) 

southeast fore reef slope but lowest (13%) on the same slope at moderate depths (30–59 feet). Sitespecific transect and photoquadrat surveys show that Pocillopora, Montipora, and Montastrea are the 

most abundant genera on the fore reef. Along the soft, unconsolidated floor of the lagoon, coral is 

found only on isolated patches of firm substrate, averaging only 0.9% cover. Average coral cover on 

the sloping rubble back reef inside the lagoon is also low (0.1%). Coral cover is higher on the 

limestone pinnacles scattered within the lagoon, averaging 10%, with the genera Favia, Montipora, 

Porites, and Astreopora as the primary components. 

Reproduction. Corals reproduce both sexually and asexually. Sexual reproduction involves the 

process of gametogenesis (generation of gametes), which may require from a few weeks for sperm to 

more than 10 months for eggs. The dominant reproductive mode of scleractinian (true stony) corals 

in the Pacific Ocean is broadcast spawning of gametes followed by external fertilization. Subsequent 

cell divisions of the fertilized eggs result in small, dispersive propagules (planula larvae) which may 

settle, metamorphose, and develop into primary polyps. The phenology of spawning and degree of 

synchrony within and between species can vary widely among locations and along latitudinal 

gradients, ranging from annual multi-species mass spawning events on the Great Barrier Reef in late 

austral spring to little apparent synchrony among species in Hawai‘i or the Red Sea. 

Relatively little is known of the phenology of coral spawning in American Samoa. Seven species 

have been observed spawning off Tutuila in the week following the October or November full moon 

(Itano and Buckley 1988, Mundy and Green 1999), and measurements of the sizes of developing 

eggs from two additional species off Tutuila also suggest spawning occurs after the October or 

November full moon (Kenyon, unpubl. data 2008). However, egg size data from several other 

species sampled off Tutuila suggest spawning is more spread out through the year and that some 

species may have at least two spawning periods in different seasons. 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

4-40 Chapter 4. Biological Environment

Limited sampling of four Acropora species on the back reef and fore reef at Rose Atoll in late 

February revealed that colonies of one species would spawn within the following month, two other 

species were nearing maturity, and one species had no gravid polyps (Kenyon, unpubl. data 2002). 

Clearly, much remains to be determined concerning coral spawning cycles at Rose Atoll and within 

the larger region of American Samoa. 

The gametes and developing embryos of most broadcast-spawning corals are positively buoyant and 

therefore vulnerable to natural and anthropogenic disturbances that can substantially impact 

successful reproduction, including lowered salinity, extremes of temperature or irradiance, turbidity, 

eutrophication, and pollution. The capacity to maintain or renew genetically diverse coral 

populations through sexual reproduction is a key attribute of reef resilience; consequently, reef 

managers’ understanding of regeneration and recovery processes is informed by knowledge of the 

timing of coral sexual reproduction. 

Asexual reproduction from coral fragments is a common process of colony replication. Asexual 

reproductive results in a new coral colony that is genetically identical to the parent colony (a clone). 

Colonies started from fragments have the advantages of large initial size and locally adapted 

genotypes. The ability of some species of Acropora to survive fragmentation and rapidly fill space 

has led to an interest in using these species for programs of reef restoration. 

Threats to Corals at Rose Atoll 

The grounding of a large steel-hulled Taiwanese 

long-line fishing vessel in October 1993 resulted 

in a fuel and ammonia spill and break-up of the 

ship into thousands of pieces during the following 

years. The cumulative impacts included massive 

kills of corals and coralline algae from the spills 

and subsequent invasion of cyanobacteria that 

were increasingly stimulated by the corrosion and 

release of dissolved iron from the metallic 

components of the wreckage. The invasive 

cyanobacteria also displaced other indigenous 

marine species over a broader area including reef 

areas beyond the spill and grounding zone. Collectively the ship grounding and its breakup fueled the 

demise of many species in the affected habitats concentrated along the southwest perimeter reef and 

adjacent lagoon where the ship struck the reef. 

From 1999 to 2007, seven visits to the Refuge by Samoan salvagers, supported by NWR funds and 

the Oil Spill Liability Trust Fund Act managed by the USCG, succeeded in removing more than 99% 

of the ship debris. Monitoring efforts since 1999, coinciding with debris cleanup efforts as well as 

cooperative surveys conducted with NMFS PIFSC, have revealed slow but persistent recovery of 

corals, coralline algae, and echinoderms that normally dominate the affected reef crests, shallow fore 

reefs, back reefs, and lagoon reefs near the grounding site (Green et al. 1997, Maragos 1994, 

Schroeder et al. 2008, Kenyon et al. 2010).

Cyanobacteria stimulated by the 1993 shipwreck 

continue to overgrow the substrate. 

Jean Kenyon/USFWS
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 4. Biological Environment 4-41

 

Maragos (1994) noted widespread bleaching of numerous species of scleractinian corals in several 

environments at Rose Atoll in March 1994 to depths of 66 feet. Concurrent widespread bleaching at 

Tutuila suggested the bleaching was a regional phenomenon related to increases in surface water 

temperatures associated with ENSO rather than the result of local perturbations caused by the 

October 1993 ship grounding and chemical spill. Nonetheless, bleaching was most pronounced along 

the southwest fore reef, and its severity increased slightly when moving towards the wreckage, a sign 

that stress to corals from the shipwreck may have contributed to the severity of the bleaching event. 

Though quantitative observations of the severity and geographical extent of bleaching at Rose Atoll 

could not be made during the 1994 event, qualitative snorkeling observations revealed that most of 

the outside perimeter of the atoll reef was consistently bleached to depths of 66 feet (Maragos 1994). 

Although the extent of subsequent mortality is unknown due to a hiatus in scientific surveys between 

1994 and 1999, quantitative observations from NMFS PIFSC monitoring surveys in 2002 and 2004 

indicate coral populations in the early stages of recovery from both the 1993 ship grounding and 

1994 bleaching event (Kenyon et al. 2010). Although the bleaching event did not result in chronic 

damage to the reefs at Rose Atoll, some reef communities shifted to other species from what was 

observed in 1994. 

The size and depth of the ava connecting the lagoon to the ocean is very important to maintaining the 

coral and other communities of Rose Atoll. Any modification to the ava would change the water flow 

regime and could exacerbate the effects of climatic warming and lead to permanent losses of corals 

during future bleaching events, especially within the lagoon where ambient temperatures are 

naturally slightly higher than deeper waters on the ocean side of the atoll (NMFS PIFSC 2008). This 

type of occurrence has already been documented at Palmyra Atoll (Williams et al. 2010). There were 

no bleaching events reported at Rose between 1995 and 2011. 

Rose Atoll before the grounding (left) and Rose Atoll after the grounding (1994). Note the discoloration (circled in 

yellow) where the cyanobacteria impacted the CCA. USFWS
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

4-42 Chapter 4. Biological Environment

Pacific-wide, there is growing concern pertaining to the threat of increased prevalence, geographic 

distribution, and host range of coral diseases. Disease is defined as any impairment that interferes 

with or modifies the performance of normal physiological functions, including responses to 

environmental factors, toxicants, and climate; infectious agents; inherent or congenital defects; or a 

combination of these factors (Wobeser 2006). Quantitative coral disease assessments conducted by 

NMFS PIFSC at 40 different U.S. Pacific coral islands, banks, and atolls between 2006 and 2007 

revealed Pacific-wide mean disease prevalence (proportion of colonies affected) was low (regional 

means less than 5%), but site-specific hotspots occurred at Rose Atoll (11.7%) and four other 

islands/atolls (Vargas-Ángel and Wheeler 2008). In addition to minor bleaching, white syndrome, 

pigmentation responses, and other lesions were documented, with algal/cyanophyte infestions 

accounting for greater than 75% of all disease cases, most notably abundant in the vicinity of the 

1993 shipwreck site. 

4.9.2 Coralline Algae 

Crustose coralline algae are an important component of reef systems, and the reefs at Rose Atoll are 

dominated by CCA. Together with hard corals, CCA represent a major source of reef limestone. The 

CCA cement and consolidate carbonate material, thus contributing to the growth and persistence of 

tropical reef structures. The capacity of coral communities on fore reefs to recover from disturbances 

is probably partially a result of the ability of CCA to bind loose rubble into a stable substratum 

(Birkeland et al. 2008). Settlement and metamorphosis of many key benthic reef elements, including 

scleractinian corals and octocorals, are induced by external biochemical cues associated with live 

CCA (Heyward and Negri 1999, Harrington et al. 2004). In addition, CCA are important sources of 

primary production. Water temperature and motion, light availability, sedimentation, and predation 

represent major influential factors determining patterns of CCA distribution, abundance, and 

zonation on tropical reef ecosystems (Littler and 

Doty1975, Fabricius and De’ath 2001). 

Although the critical importance of CCA to the 

formation and ecology of tropical reefs is well 

documented, many aspects of the biology, ecology, 

and taxonomy of this flora are still poorly understood 

(Chisholm 2003). The CCA only live in marine waters, 

and they are hard because of calcareous deposits 

contained within the cell walls. They are typically pink 

or some other shade of red. Coralline algae are in the 

order Corallinales, in the red algal division 

Rhodophyta. Coralline algae have typically been 

divided into two groups based on their morphological 

form (though this division does not constitute a 

taxonomic grouping): the geniculate (articulated or connected by a flexible joint) corallines and the 

nongeniculate (nonarticulated) corallines. Geniculate corallines (e.g., Jania sp.) are branching, treelike plants that are attached to the substratum by calcified, root-like holdfasts. The plants are made 

flexible by having noncalcified sections (genicula) separating longer calcified sections 

(intergenicula). Nongeniculate corallines range from a few micrometers to several-centimeter-thick 

crusts; there are more than 1,600 described species of nongeniculate coralline algae. Those with a 

growth habit that closely adheres the thallus to the substrate are commonly called CCA (Porolithon

sp., Hydrolithon sp., Lithothamnion sp.). 

A diver conducts a quantitative survey of 

corals and CCA along a transect line. 

Jean Kenyon/USFWS
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 4. Biological Environment 4-43

Mayor (1924) noted that the exceptionally well-developed shallow calcareous algal ridge at Rose 

Atoll had the densest growth of calcareous algae he had encountered anywhere, and suggested it 

could be called a “Lithothamnion-atoll rather than a coral atoll”. Observations following the 1993 

longliner grounding indicated that the reef flat coralline algal community was severely affected and 

significantly altered by the petroleum released during the grounding. A massive die-off of CCA, 

extending 3,279 feet along the reef flat and reef margin, occurred on the southwest arm of the atoll 

where the vessel grounded (Maragos 1994). The large-scale die-off of the CCA was accompanied by 

a bloom of invasive cyanobacteria that were previously uncommon on the atoll. Within a year, the 

cyanobacteria had spread across the atoll’s entire southwest arm and had begun to invade adjacent 

areas of the lagoon as well as portions of the northwest arm (Green et al. 1997). Quantitative surveys 

of CCA and cyanobacteria cover using transects along the seaward, mid-reef, and lagoon edge of the 

southwest arm of the reef flat were conducted in 1995, 1996, 1998, and 2002. In contrast to other 

arms of the atoll, which are pink in color due to the dominance of CCA, in 1995, 2 years after the 

spill, the southwest arm had very low abundance (less than 20% cover) of this key algal group. On 

the outer (seaward) reef edge, CCA was absent except at the northern end of the arm. In 1996, 1998, 

and 2002 CCA abundance had steadily increased on the outer edge, except near the wreck site; an 

area of low CCA cover (approximately 10%) had persisted near the wreck even following debris 

removal efforts. On the inner (lagoon) edge of the reef flat, cover of CCA was highly variable in the 

survey years and in 2002 had dropped to low levels (less than 30%), especially at the southern end of 

the southwest arm (Burgett 2003). Removal of remaining visible metallic debris from the grounding 

was completed in 2007, and the last transect surveys to monitor whether a more natural algal 

community is developing on this arm of the reef flat were done in 2010. 

Although the fore reef slopes are not included within the Refuge boundaries, its biological 

communities serve as sources of colonizing propagules to those protected within the Refuge. In 2002, 

average CCA cover derived from quantitative analysis of imagery recorded during towed-diver 

surveys that circumnavigated the Rose Atoll fore reef in 3 depth strata was 48% (Kenyon et al. 

2010), more than twice the average cover provided by corals (23%). Mean CCA cover was highest 

(65%) on the shallow (less than 30 feet) southwest fore reef slope and lowest (27%) on the deep 

(greater than 59 feet) northeast fore reef. On all four fore reef exposures (northeast, southeast, 

southwest, northwest), mean CCA cover decreases as depth increases from shallow to moderate (30–

59 feet) to deep depth strata (Kenyon et al. 2010). 

The distinctive crustose coralline algal reef crest, with Rose Island in the background (left photo). Close up of CCA (right 

photo). Jean Kenyon/USFWS
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

4-44 Chapter 4. Biological Environment

Although there is growing consensus pertaining 

to the increased threat of disease to corals, little 

is known about coralline algal disease 

distribution, abundance, and the potential 

implications to declining CCA flora. 

Quantitative coral disease assessments 

conducted by NMFS PIFSC at 42 different U.S. 

Pacific coral islands, banks, and atolls between 

2006 and 2008 revealed the highest average 

CCA percent cover occurred at Rose Atoll 

(Vargas-Ángel 2010). In 2006, of the 

islands/atolls in American Samoa, Rose Atoll 

had the lowest ratio of the number of cases of 

CCA disease relative to percent cover (0.1), but 

in 2008 this ratio had significantly increased to 

0.8. While this U.S. Pacific-wide study could not 

make clear large-scale patterns linking CCA disease occurrence with natural reef physiographic or 

geomorphological features (e.g., carbonate vs. volcanic islands; windward vs. leeward wave 

exposures), the author noted that at Rose Atoll and a few other locations, leeward and protected 

habitats exhibited 60% more CCA disease cases when compared to exposed windward sites. 

4.10 Fish

The number of reef fish species at Rose Atoll is estimated to be 272, based upon surveys conducted 

from 1981 to 2004 (Wegmann and Holzwarth 2006) (Appendix A). While this is a subset of the 991 

reef fish species listed for all of American Samoa and Samoa in Wass (1984), the proportion found at 

Rose is substantial given that the atoll has less than 1% of the total reef habitat in the archipelago. 

Reef fish living amongst or in close proximity to tropical reefs have evolved many specializations 

adapted to survival on the reef. Their range of feeding strategies includes herbivores that graze on 

benthic algae, corallivores that feed on coral polyps, generalized carnivores that feed on a variety of 

animal prey, and specialized carnivores with more focused animal prey preferences such as 

zooplankton. 

Reef fish surveys at Rose Atoll have documented an assortment of reef fish families and genera 

similar to other central Pacific shallow reefs (Green 1996, Whaylen 2005, NMFS PIFSC 2008). 

Damselfishes, surgeonfishes, wrasses, and parrotfishes were the most common families of small (less 

than 8 inches total length [TL]) to medium (8–20 inches TL) reef fish encountered. Snappers 

(Lutjanidae), groupers (Serranidae), and jacks (Carangidae) were the most common large (greater 

than 20 inches TL) reef fishes observed at Rose Atoll. Sharks (Carcharhinidae) were present but 

uncommon, mainly seen in shallow water on the fore reef just below the surf. 

Reef fish surveys conducted by NMFS PIFSC using standardized methods showed that mean fish 

biomass per reef area at Rose Atoll is higher than at Tutuila but significantly lower than at other 

Pacific Remote Island refuges distant from human population (Howland, Baker, and Jarvis Islands, 

Johnston, Palmyra, and Wake Atolls, Kingman Reef) (Williams et al. 2011). At Rose Atoll, fish 

biomass appears to be highest inside the lagoon and on the southwest fore reef compared to other 

areas of the atoll (NMFS PIFSC 2008). Small to medium-sized fish were very abundant around 

Herbivorous fishes (here, a school of surgeonfishes) are 

abundant where cyanobacteria and turf algae have 

proliferated as a long-term response to shipwreck metallic 

debris. Jean Kenyon/USFWS
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 4. Biological Environment 4-45

several of the larger pinnacle patch reefs inside the lagoon, where parrotfish, snapper, emperor, 

goatfish, and jacks were common. Herbivores (surgeonfish, parrotfish, and angelfish) were abundant 

on the southwest fore reef, with significantly greater numbers and biomass at the site of the 1993 

longliner grounding than at neighboring sites (Schroeder et al. 2008). This greater abundance of 

herbivores at the impact site was associated with significantly greater substrate cover of turf algae 

and cyanobacteria. The highest densities of large fish (greater than 20 inches TL), such as jacks and 

barracuda, were recorded just outside the ava along the northwest fore reef. This may be a preferred 

site for feeding on prey or plankton flowing out of the lagoon or may be a preferred site for spawning 

activity (NMFS PIFSC 2008). 

Of concern is the conservation status of two species previously found at Rose Atoll: the Maori 

wrasse, Cheilinus undulatus, and the bumphead parrotfish, Bolbometapon muricatum. Both of these 

species have been subject to heavy fishing pressure. However, in response to a listing petition under 

the ESA, NOAA NMFS recently completed a 

status review of the bumphead parrotfish and 

determined that listing as an endangered or 

threatened species was not warranted. (77 

Fed.Reg. 66799 November 7, 2012). 

The peppered moray (Gymnothorax pictus) is 

commonly found in shallow water up on the 

reef flat at Rose where it feeds on crustaceans 

and fish (Lieske and Myers 1994). Its size, (up 

to 4.5 feet long), its abundance at Rose, and 

habit of coming out of the water in pursuit of 

prey makes it a good candidate for long-term 

monitoring. It is distributed throughout the Indo-Pacific and Eastern Pacific: East Africa to the 

Galapagos, Cocos, and Clipperton islands; north to the Hawaiian and Ryukyu islands; and south to 

Australia and the Kermadec Islands (Chen et al. 1994). 

Sharks are a group of fishes characterized by a cartilaginous skeleton and 5–7 gill slits on the sides of 

the head. There are more than 440 species of sharks belonging to 8 taxonomic orders. The three 

species of shark that have been recorded at Rose Atoll NWR (gray reef shark, blacktip reef shark, 

and whitetip reef shark; Carcharhinus amblyrhychos, Carcharhinus melanopterus, and Triaenodon 

obesus, respectively) belong to the order Carcharhiniformes, family Carcharhinidae, commonly 

known as requiem sharks. They are distinguished by an elongated snout, a nictitating membrane that 

protects the eyes during an attack, and viviparity 

(live birth). These three species are the most 

common sharks inhabiting Indo-Pacific reefs. 

The gray reef shark, which is found as far east as 

Easter Island and as far west as South Africa, is 

most often seen in shallow water near the dropoffs of coral reefs, and less commonly within 

lagoons or open ocean. They are agile predators 

that feed primarily on bony fishes and 

cephalopods (e.g., octopi, squid). Despite their 

moderate size, their aggressive demeanor enables 

them to dominate many other shark species on 

Divers from NMFS PIFSC conduct surveys for reefassociated fish along transect lines. Jean Kenyon/USFWS

Malie alamata in Rose Atoll lagoon. Kelsie Ernsberger/USFWS
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

4-46 Chapter 4. Biological Environment

the reef. Many gray reef sharks have a home range on a specific area of the reef to which they 

continually return. Gray reef sharks were the first shark species known to perform a threat display, a 

stereotypical behavior warning that it is prepared to attack. The display involves a hunched posture 

with dropped fins and an exaggerated, side-to-side swimming motion. They do so if they are 

cornered by divers, indicating they perceive a threat. This species has been responsible for a number 

of attacks on humans, so should be treated with caution, especially if they begin to display. They are 

caught in many fisheries and are susceptible to local population depletion due to their low 

reproductive rate (litters of 1–6 pups are born every other year) and limited dispersal. As a result, the 

IUCN has assessed this species as Near Threatened (Smale 2009). 

The malia alamata (blacktip reef shark), found throughout the nearshore waters of the tropical and 

subtropical Indo-Pacific, prefers shallow, inshore waters. It is usually found in water only a few 

yards deep and can often be seen swimming close to shore with its black-tipped dorsal fin exposed. 

Younger sharks prefer shallow, sandy flats, while older sharks are most common around reef ledges 

and near reef drop-offs. A tracking study off Palmyra Atoll in the central Pacific found the malie 

alamata had a home range of about 0.21 square mile, among the smallest of any shark species 

(Papastamatiou et al. 2009). Often the most abundant apex predator in its ecosystem, the malie 

alamata plays a major role in structuring inshore ecological communities. Its diet is composed 

primarily of small bony fish, though cephalopods are also consumed. Sharks off Palmyra Atoll have 

been documented preying on seabird chicks that have fallen out of their nests into the water 

(Papastamatiou et al. 2009). Under most circumstances, the malie alamata has a timid demeanor and 

is easily frightened away by swimmers. However, its inshore habitat preferences bring it into 

frequent contact with humans, and thus it is regarded as potentially dangerous. Though it remains 

widespread and common overall, substantial local declines due to overfishing have been documented 

in many areas. This species has a low reproductive rate, with a litter size of 2–5 pups, limiting its 

capacity for recovering from depletion. The IUCN has assessed the malie alamata as Near 

Threatened (Heupel 2009). 

The whitetip reef shark, which is found as far east as Central America and as far west as South 

Africa, is typically found on or near the bottom in clear, shallow water. The habitat preferences of 

this species overlap those of the malie alamata and the gray reef shark, though it does not tend to 

frequent very shallow water like the malie alamata or the outer reef like the gray reef shark. Unlike 

other requiem sharks, which rely on ram ventilation and must constantly swim to breathe, the 

whitetip reef shark can pump water over its gills and lie still on the bottom. During the day whitetip 

reef sharks spend much of their time resting beneath overhangs or in caves, emerging at night to hunt 

bony fishes, octopi, and crustaceans. Individual whitetip reef sharks may stay within a particular area 

of the reef for months to years, returning time and again to the same shelter. Females give birth to 1–

6 pups every other year. Whitetip reef sharks are rarely aggressive towards humans, though they may 

investigate swimmers closely. The IUCN has assessed the whitetip reef shark as Near Threatened, 

noting that its numbers are dwindling due to increasing levels of unregulated fishing activity across 

its range (Smale 2005). The slow reproductive rate and limited habitat preferences of this species 

renders its global populations vulnerable to over-exploitation. 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 4. Biological Environment 4-47

4.11 Invasive and Nuisance Species

Invasive species displace native vegetation, alter the composition and structure of vegetation 

communities, affect food webs, and modify ecosystem processes, resulting in considerable impacts to 

native wildlife. For the purpose of this CCP, “invasive” is a subset of nonnative species or 

indigenous species that have started to proliferate and modify the species composition or function of 

the existing native community, typically due to some human action. 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. 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. The cyanobacteria previously discussed is an example of a native species that has 

become invasive.

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. Islands which have existed in isolation for millions of years are ideal environments for 

invasive species. Most native species have evolved without the necessity for defense and therefore 

lost their natural defense mechanisms and are more vulnerable to introduced species. Island 

ecosystems are key areas for conservation of global biological diversity. While islands make up only 

about 3% of the earth’s surface, they are home to 15–20% of all plant, reptile, and bird species 

(Whittaker 1998). Small population sizes and limited habitat availability make species endemic to 

islands especially vulnerable to extinction and their adaptation to isolated environments makes them 

particularly vulnerable to aggressive introduced species (Diamond 1985, Diamond 1989, Olson 

1989). Of the 484 recorded animal species extinctions since 1600, 75% were species endemic to 

islands (World Conservation Monitoring Center 1992).

4.11.1 Mammals

The impacts from invasive predatory mammals are one of the leading causes of species extinction on 

islands (Blackburn et al. 2004, Duncan and Blackburn 2007). Rats living in close association, or 

commensally, with humans (Norway rat, Rattus norvegicus; black rat, R. rattus; and Polynesian rat, 

R. exulans) have been introduced to about 90% of the world’s islands and have a pronounced effect 

on island ecosystems (Towns et al. 2006). In addition, the extinction of many island species of 

mammals, birds, reptiles, and invertebrates have been attributed to the impacts of invasive rats 

(Andrews 1909, Daniel and Williams 1984, Meads et al. 1984, Atkinson 1985, Tomich 1986, Hutton 

et al. 2007), and estimates of 40-60% of all recorded bird and reptile extinctions globally were 

directly attributable to invasive rats (Atkinson 1985, Island Conservation n.d.). 

Even if species are not extirpated, rats can have negative direct and indirect effects on native species 

and ecosystem functions. For example, a comparison of rat-infested and rat-free islands, and pre- and 

post-rat eradication experiments have shown that rats depressed the population size and recruitment 

of birds (Campbell 1991, Thibault 1995, Jouventin et al. 2003), reptiles (Whitaker 1973, Bullock 

1986, Towns 1991, Cree et al. 1995), plants (Pye et al. 1999), and terrestrial invertebrates (Bremner 

et al. 1984, Campbell et al. 1984). In particular, rats have significant impacts on seabirds, migratory 

shorebirds, and other birds by preying upon eggs, nestlings, chicks, and adults and causing 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

4-48 Chapter 4. Biological Environment

population declines, with the most severe impacts on burrow-nesting seabirds (Atkinson 1985, 

Towns et al. 2006, Jones et al. 2008). Ground- and burrow-nesting seabirds are particularly 

vulnerable to rat predation. 

In addition to preying on seabirds, introduced rats feed opportunistically on plants, and alter the floral 

communities of island ecosystems (Campbell and Atkinson 2002); in some cases degrading the 

quality of nesting habitat for birds that depend on the vegetation. Small, oceanic islands have 

simplified seed dispersal systems that generally lack mammalian vectors and are vulnerable to 

disruption by invasive species (Drake et al. 2002). Rats can disrupt seed dispersal mutualisms by 

depositing seeds in microhabitats that are ill-suited for germination or subsequent growth. Native 

crab species prey on seeds as well, although they only eat the fleshy pulp, leaving the seed coat 

intact, allowing the seed to germinate. Rats are able to consume the fleshy pulp and chew through the 

seed coat killing the existing seed and preventing germination and recruitment of native plants. It is 

possible that rats can also indirectly reduce plant fitness by reducing the effectiveness or numbers of 

native dispersers through competition and predation (Wegmann 2009). 

On Tiritiri Matangi Island, New Zealand, ripe fruits, seeds, and understory vegetation underwent 

significant increases after rats were eradicated from the island, indicating the rats’ previous impacts 

on the vegetation (Graham and Veitch 2002). At Palmyra Atoll, in a very similar Pisonia-dominated 

coastal strand forest ecosystem, an eradication project to eliminate Rattus rattus was implemented in 

June 2011. By August of that year total counts of all tree seedlings in 56 transects had increased 

significantly, including those of native pu’a vai changing from no seedlings detected before 

eradication to 12.3 seedlings per transect post-eradication. Seedling censuses under five rare native 

tree species showed significant increases between 2004 and post-eradication, including the first ever 

documentation of seedling Cordia subcordata at Palmyra. This species was first detected at Rose in 

1994 after Rattus exulans was removed there (USFWS 2011). 

Rats are also documented to directly affect the abundance and age structure of intertidal invertebrates 

(Navarrete and Castilla 1993), indirectly affect species richness and abundance of a range of 

invertebrates (Towns et al. 2009), and contribute to the decline of endemic land snails in Hawai‘i 

(Hadfield et al. 1993), Japan (Chiba 2010), and American Samoa (Cowie 2001). 

Polynesian rats are speculated to have been a contributing factor in the large-scale extinctions of 

Hawaiian bird species during Polynesian settlement prior to European contact. Rats also consume 

plants, insects, mollusks, herpetofauna, and other invertebrates (Olson and James 1982, Brisbin et al. 

2002, Engilis et al. 2002, Mitchell et al. 2005). 

Polynesian rats and humans are the only known terrestrial mammals to reach Rose Atoll. The rats 

were first documented in 1920 (Mayor 1924). Rats have a varied diet that includes seabirds and turtle 

eggs and hatchlings as well as a variety of plants and their seeds. The population of rats on Rose 

Island was estimated to be 1,000–1,600 in 1990. Rats were eradicated in an operation beginning in 

1991 by the Service under the guidance of U.S. Department of Agriculture Wildlife Services using 

live traps, kill traps, and bait stations armed with Talon ® anti-coagulant rodenticide containing 

brodifacoum spaced 82 feet apart over the entire island. No rats have been detected on the island 

since. 

Subsequent to the eradication of Polynesian rats at Rose, the number of plant species has increased 

from only four species on Rose Island in 1990 to at least eight species in 2010. While it is likely that 

rat eradication provided a beneficial effect for all nesting seabirds at Rose, the only species for which 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 4. Biological Environment 4-49

Oceanic gecko. USFWS

adequate pre- and post-eradication data exist to demonstrate a statistically significant effect was the 

red-tailed tropicbird (Wegmann and Holzwarth 2006). 

4.11.2 Reptiles

Reptiles have not been well studied at Rose Atoll. There are at least two species of gecko on Rose 

Island: the Oceanic gecko (Gehyra oceanica) and the mourning gecko (Lepidodactylus lugubris) 

(Amerson et al. 1982), which were likely introduced by humans but are indigenous to the central 

tropical Pacific and at present do not show signs of posing a threat to BIDEH. 

4.11.3 Invertebrates

Invasive ants and scale insects (Pulvenaria urbicola) have contributed to mortality of Pu’a vai at 

Rose Island. These insects work together to invade and feed on sap from the leaves and petioles of 

the trees. The ants defend the scale insects and “farm” them for the concentrated liquid that they 

exude. This weakens the trees and may cause them to repeatedly shed their foliage until they 

eventually die. In 1994 Rose Island was covered with a thick forest of pu’a vai, but by 2005, all but 

about 11 trees had perished. The surviving trees were treated with systemic imidacloprid. In 2010, 

three of the treated trees remained alive but not healthy. The ants and scale invaders may have 

reached Rose Island on plantings and food or packing material of human visitors in recent decades. 

4.11.4 Vegetation

Coconut trees were first observed on Rose Island in the mid-19th century and were likely planted by 

Samoan visitors (Setchell 1924). Mayor’s 1920 scientific account of Rose Atoll recorded about 6 

coconut trees remaining of about 15 that were 

planted in 1902 and 1920 by Governors Tilly and 

Terhune (Mayor 1921). Amerson and colleagues 

(Amerson et al. 1982) mapped 13 trees on the 

island in the mid-1970s. The Department of 

Agriculture visited Rose Atoll in 1957 and planted 

50 coconut seedlings (Swerdloff and Needham 

1970). In 1987, a DMWR expedition mapped 30 

coconut trees on Rose, including several trees 

planted around the island by a “vessel crew” the 

previous year. Several trip reports make note of the 

coconut infestation and call for management 

(Shallenberger 1980). 

The elimination of rats in 1991 allowed many more nuts to germinate. In 2005, Hurricane Olaf 

uprooted many of the native canopy trees on Rose Island. Three dense patches of adult coconut trees 

survived and by 2010 had spread. Niu are very aggressive in displacing indigenous shrubs and trees 

because the nuts form an impenetrable mat over the ground and form a shading canopy monoculture 

that prevents the recruitment of native canopy trees. In 2010, Refuge and DMWR staff and 

contractors removed and destroyed 1,038 sprouted nuts, 94 green nuts from the trees, and 38 young 

palms. An additional 42 large palms were treated by drilling holes in the stem and applying 

glyphosate. They left one large coconut tree undisturbed in each of the three patches. 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

4-50 Chapter 4. Biological Environment

In 1994, patches of the nonnative grasses Cenchrus echinatus and Chloris barbata were removed 

from Rose Island (Craig et al. 1994), and a few individuals have had to be removed since then. No 

plants of either species were detected in 2010. 

4.12 Wildlife and Habitat Research Inventory and Monitoring 

Several scientific expeditions to Rose Atoll took place during the 1930s. In 1937 and 1938, Wray 

Harris, a scientist at the Bishop Museum, visited Rose Atoll to collect samples of mollusks and plants 

(Sachet 1954). The USCG brought a group of scientists to Rose Atoll in 1938; the observations were 

published by E.H. Bryan in 1939 and 1942 and W. Donaggho in 1953. In 1939, the U.S.S. Bushnell

conducted a survey of islands in the Pacific and 11 days were spent collecting specimens of fish from 

Rose Atoll (Sachet 1954). Under Executive Order 8683, President Franklin Delano Roosevelt 

designated Rose Island as a Naval Defense Sea Area on February 14, 1941. The United States Navy 

Hydrographic Office published a map of Tutuila, the Manu’a Islands, and Rose Island in 1941. The 

data were gathered between 1901 and 1939 (Hudson and Hudson 1994). 

In February 1953, the Office of the Territories, DOI conducted a fishing survey at Rose Atoll (Sachet 

1954). In 1968, Rose Atoll was proposed as an “Island for Science” under the International 

Biological Programme (UNEP and IUCN 1988, IUCN 1991). The ASG sponsored a 1970 survey of 

Rose and Sand Islands, the reef flats, and the surrounding lagoon. The 1970 survey stressed the 

importance of Rose Atoll to breeding seabirds and i’a sa and recommended the atoll be designated a 

wildlife preserve (Swerdloff and Needham 1970). Between the years 1973 (the Refuge’s 

establishment) and 2005, 49 documented expeditions visited Rose Atoll (Wegmann and Holzwarth 

2006). The Service and ASG have cooperated on scientific visits and aerial reconnaissance trips to 

the Refuge. Between 2002 and 2012, the NMFS PIFSC organized and conducted biennial American 

Samoa Reef Assessment and Monitoring research cruises. 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 5. Social and Economic Environment 5-1 

Chapter 5. Social and Economic Environment

5.1 Cultural Resources 

Archaeological and other cultural resources are important components of our nation’s heritage. The 

Service is committed to protecting valuable evidence of plant, animal, and human interactions with 

each other and the landscape over time. These may include previously recorded or yet undocumented 

historic, cultural, archaeological, and paleontological resources as well as traditional cultural 

properties and the historic built environment. Protection of cultural resources is legally mandated 

under numerous Federal laws and regulations. Foremost among these are the NHPA, as amended, the 

Antiquities Act, Historic Sites Act, Archaeological Resources Protection Act, as amended, and 

Native American Graves Protection and Repatriation Act. Additionally, the Refuge seeks to maintain 

a working relationship and consult on a regular basis with villages that are or were traditionally tied 

to Rose Atoll. 

5.1.1 Historical Background

The seafaring Polynesians settled the Samoan Archipelago about 3,000 years ago. They are thought 

to have been from Southeast Asia, making their way through Melanesia and Fiji to Samoa and 

Tonga. They brought with them plants, pigs, dogs, chickens, and likely the Polynesian rat. Most 

settlement occurred in coastal areas and other islands, resulting in archaeological sites lost to ocean 

waters. Early archaeological sites housed pottery, basalt flakes and tools, volcanic glass, shell 

fishhooks and ornaments, and faunal remains. Stone quarries (used for tools such as adzes) have also 

been discovered on Tutuila and basalt from Tutuila has been found on the Manu’a Islands. Grinding 

stones have also been found in the Manu’a Islands. Despite surveys, no quarries have been identified 

in Manu’a (ASHPO 2012). 

In the later period of Samoan pre-contact, warfare for titled positions was frequent in Samoa and it 

likely influenced Tutuila and Manu’a. Oral traditions in the Manu’a Islands refer to leaders of islands 

to the west (Fiji, Samoa, etc.) visiting on sometimes hostile missions. Defensive fortification sites, 

often located high on ridges and mountains, define this period, with one such structure in Tutuila (a 

large defensive wall) on the National Register of Historic Places and another structure (fortification) 

on Ofu Island planned for nomination to the National Register. A typical layout of a Samoan village 

was a central open space (malae), surrounded by meeting houses, chiefs’ houses, other residences, 

and cooking houses (ASHPO 2012). 

European contact occurred in 1722, with Dutch navigator Jacob Roggeveen followed by French 

explorers Louis-Antoine de Bougainville in 1768 and Jean-Francois de La Perouse in 1787. 

Englishman John Williams of the London Missionary Society arrived in 1830, bringing with him 

Christianity which changed Samoan culture and ways. It was also when Westerners started to settle 

these islands. European traders and military personnel also changed Samoan society. Local warfare 

ceased, quarries were abandoned with the introduction of metal tools, and local customs and 

practices changed (ASHPO 2012). 

The Tripartite Convention of 1899 formally partitioned the Samoan Archipelago into a German 

colony and a U.S. territory. This convention resulted from several years of civil war among Samoan 

factions and the rivalry between the U.S., Germany, and Britain. The U.S. acquired the eastern 
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5-2 Chapter 5. Social and Economic Environment

islands, while Germany took control of what now comprises Samoa, which New Zealand forces took 

from the Germans in 1914 until 1962 (ASHPO 2012). 

American Samoa, under U.S. Naval control from 1900 to 1951, was a coaling station for its fleets. 

World War II (WWII) began the transition of the economy from subsistence toward commercial. The 

U.S. Naval Station Tutuila (now a Historic District listed on the National Register) was the 

headquarters of the Samoan Defense Group, which included several adjacent island groups. Historic 

properties from WWII are found throughout the islands. Post WWII, American Samoa’s military 

importance declined and the 1940s and 1950s saw severe economic distress with the Navy leaving. 

This period started the exodus of the Samoan workforce to Hawai‘i and the mainland U.S. In 1951, 

the administrative responsibility for coordinating Federal policy to the Territory was transferred to 

the DOI, where it remains today. Between 1951 and 1977, Territorial Governors were appointed by 

the Secretary of the Interior; but since 1977, they have been elected by universal suffrage (ASHPO

2012). American Samoa has its own constitution, its own legislature, its own court system, and a 

non-voting delegate in the U.S. House of Representatives. 

Starting in 1954, the tuna industry started to invest in American Samoa with the opening of canneries 

by the Van Camp Seafood Company of California and Starkist Incorporated. It became a major 

industry for the Territory, attracting workers from Samoa as well as China. This last decade has seen 

a decline, however, with the canneries downsizing or shutting down (ASHPO 2012). 

Despite its post-contact history and Western interactions, the Samoan culture and societal structure 

remains strong (often reflected in the phrase fa’a Samoa or the Samoan way of life). Communal or 

aiga (family) land and matai (chief) systems remain intact. The matai are divided into ali’i (high 

chiefs) and tulafale (talking chiefs or orators who usually serve as executive agents for ali’i). The 

basic unit of Samoan society, the aiga or extended family group, is a group of people related by 

blood, marriage, or adoption. This family group can number from a few to several hundred who also 

acknowledge a common allegiance to a particular matai. The matai possesses some authority over 

the members of his family and regulates some of their activities as well as family resources 

(especially land–up to 90% of land in American Samoa is communally owned). However, 

traditionally, the matai consults the aiga before exercising his authority. The matai title holder will 

always be from the same family line. A non-family/descent line cannot hold a ranking matai title 

within a family. The resilience of the Samoan culture also has to do with its preservation being 

codified in its Bill of Rights (Article 3) and American Samoa Code Annotated (Title 1, section 

1.0202). 

5.1.2 Rose Atoll and Manu’a Islands

The Manu’a Islands are comprised of Ofu, Olosega, and Ta’ū Islands, and Rose Atoll. Manu’a 

contains the origins of Samoans and the genealogy of Polynesians east of Samoa is said to have 

originated here. The Solo’o Va recounts the creation of Samoa and Manu’a is described as the first of 

lands, and the high peak of the island of Ta’ū, home of Tagaloa (the earthly offspring of the creator 

god). As such, the islands of Manu’a are considered sacred and the title of Tui Manu’a, seen as being 

the highest in rank of all the chiefly titles of Samoa. When the last Tui Manu’a died in 1909, the Tui 

Manu’a title was distributed amongst the different villages in Manu’a (e.g., Tui Olosega, Ofu). 

The Manu’a Islands were always independent of the other Samoan Islands, though songs, stories, and 

genealogies show contact occurred among all the islands. It was known that De Bougainville had 

traded with Manuans at Ofu in 1768, but did not land (Taomia 1997). John Williams and other 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 5. Social and Economic Environment 5-3 

Christian missionaries arrived in Manu’a in 1832. The cession of the Manu’a Islands to the U.S. 

occurred in 1904 and included Rose Atoll (though it is said that the Tuimanu’a at the time traveled to 

Rose Atoll after this partition and took with him a flag representing the five islands of Ofu, Fo’isia, 

Olosega, Ta’ū, and Rose Atoll which he staked at the atoll to reassert his authority [SSI 2012]). The 

Manu’a Islands form, administratively, the Manu’a District, one of three districts in American 

Samoa. Ofu, Olosega, and Ta’ū are all high islands and all lands are communally owned. Ta’ū is 

physically the largest island. Villages in Manu’a usually number about 300 people. Local farming 

and fishing is prevalent. The Manu’a Islands were also where famed anthropologist Margaret Mead 

did her research (in the village of Ta’ū) and based her 1928 book Coming of Age in Samoa. 

Although archaeological studies have been conducted on the Manu’a Islands, prior to 2012, none of 

the studies included Rose Atoll. The people of Ta’ū tend to call the atoll Muliāva, which means “the 

end of the reef” or Muli A’au which means “the last reef” (Gray 1960, Krämer 1995), while the 

people of Ofu tend to refer to the atoll as Nu’u of Manu, meaning “village of seabirds” (Krämer 

1995, Maragos, pers. comm. 2010). Other less common names include Motu o Manu (island of 

seabirds) and Nu’umanu (place of the sea monsters). Written documentation of historical uses of 

Rose Atoll by the Samoans is extremely limited, as the primary method of passing down information 

through the generations was through oral tradition. However, in general, Samoans believe that their 

relationship to lands and contiguous reefs and seas is a covenant with the Almighty. Samoans were 

gifted these resources to use for sustenance and their perpetuation, but also given the responsibility to 

properly conserve and husband these resources (SSI 2012). It is said that the Tui Manu’a routinely 

visited the atoll. The kings of Samoa would assemble near the atoll and often participated in games 

and leisurely activities, which included the snaring of terns. Due to the use of the atoll by the high 

chiefs, it was considered sacred and visitors were forbidden from setting foot on the atoll. The atoll 

was also believed to be guarded by ilamutu (supernatural protectors) (SSI 2012). 

According to local knowledge, the Manuans used celestial navigation to reach Rose Atoll. Rose Atoll 

is featured in a Manuan chant entitled “O le Solo a Fitiaumua” (Krämer 1995). The song tells the 

story of a husband and wife chased away from their home in Fitiuta after the husband stole food from 

a chief’s taro plantation for his starving pregnant wife. The couple was banished, set adrift on the 

ocean and landed at Rose Atoll, where they had a son, Fitiaumua. When the boy became an adult, he 

learned of his parents’ story and sought revenge. He overran and conquered Samoa, Fiji, and Tonga 

in a war, and became a successful king residing in Manu’a. 

Samoan islanders visited Rose Atoll to fish and collect birds (including feathers for cultural 

adornments and handicrafts, the most prized of which came from the red and white-tailed 

tropicbirds), turtles, faisua, and other resources (Amerson et al. 1982). Terns were especially used to 

direct fishermen to schools of fish. It was customary for the strongest males of Manu’a to go out with 

the tautai (master fishermen) to fish for sharks and skipjack tuna. However, the 2012 Samoan Studies 

Institute report notes that of the fishermen who had been interviewed (all in their 60s), none had been 

to Rose Atoll until the 2011 trip and that it had been their father’s generation who had first-hand 

experience fishing at the atoll. The report also noted that a village men’s group described that fishing 

trips to Rose Atoll were only conducted when season fish were not abundant in immediate waters 

and reefs (SSI 2012). 

Many of the seabirds found at Rose Atoll are also reflected in Samoan sayings, such as: Seu le manu 

ae taga’i i le galu (refers to the boobies)–applied in advising one to take caution; Taape le 

fuāmanusina (refers to the tropicbirds)–used at the closing of meetings to mean that everyone will 

depart together; Ua pafuga le ā e pei o le faiva o le seugā gogo (refers to terns and the sound of their 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

5-4 Chapter 5. Social and Economic Environment

calls)–said in happy salutations and occasions. There are also similar sayings related to sharks (SSI 

2012). 

Samoans also brought volcanic rocks to use as cooking stones when they fished and hunted turtles 

(Keating 1992). However, because Rose Island has no fresh water, visitors likely stayed for short 

durations. The first recorded Western sighting of Rose occurred in July 1722 by Dutch explorer 

Jacob Roggeveen, who referred to the atoll as “foul island” after observing the island was surrounded 

by a reef of rocks and had a low elevation (Sharp 1970, Krämer 1995). However, the atoll was given 

its lasting Western name in 1819 by French navigator Louis de Freycinet who named it after his wife. 

Louis de Freycinet was the Commander of the French vessel L’Uranie on a voyage of discovery that 

circumnavigated the globe. The 22-year-old Rose de Freycinet was smuggled on board dressed as a 

man and also has Cape Rose in Western Australia named after her (Bassett 1962, Western Australia 

Museum 2012, Sharp 1970). 

Additional western observations came in 1824 by Russian explorer Otto von Kotzebue and 

Frenchman Dumont D’Urville in 1838. The first recorded landing at Rose was documented by 

Captain Charles Wilkes of the U.S. Navy. He led an expedition to the atoll in 1839 where botanists 

and an anthropologist collected specimens. Two plants, Portulaca and Pisonia grandis, were 

recorded. 

The only documented case of people living on 

Rose Atoll came in the 1860s when a German 

company bought the right to establish a fishing 

station and coconut plantation from the Tui 

Manu’a (High Chief of the Manu’a Islands) and 

a Samoan family was stationed on Rose Island 

for a few years (Gray 1960, Sachet 1954). In 

1990 the remains of the foundation of a fale

(traditional Samoan house) that could have 

dated to the 1860s was located by David 

Herdrich from ASHPO (Herdrich, pers. comm. 

2011). 

In January 1920, Governor Terhune went to 

Rose Island and erected a concrete monument 

commemorating the visit with the words “Rose 

Island, American Samoa, Trespassing 

Prohibited, Warren J. Terhune Governor, 

January 10, 1920”. The monument is 4 feet 

high, 4 feet wide, and 1 foot thick. It is still on 

the island but is no longer standing upright due to unstable ground. The area is presently a 

Tournefortia forest and the monument is no longer visible from the water or beach. There is a 

second, smaller concrete U.S. Navy survey marker. It had fallen over as well, but was righted in 

March 2008 during a NOAA CRED mission which included Governor Tulafono. 

Fallen monument and location of former Refuge sign. 

USFWS
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 5. Social and Economic Environment 5-5 

Rose Island is subject to wash overs by waves during hurricanes, making it a poor environment for 

maintaining archeological artifacts. There are no historic properties at the atoll. 

There are four known records of shipwrecks in the area: schooner Friendship (1849), schooner 

Wakulla (1853), schooner Good Templar (1868), and the fishing vessel Jin Shiang Fa (1993). The 

Jin Shiang Fa ran into the southwest section of the atoll and broke apart. The largest sections of it 

were towed off the reef and dumped in the deep ocean, but pieces of it may still wash up on the reef 

in hurricanes to this day. There are no signs of the older wrecks. 

A pre-contact canoe anchor was found at Rose Atoll 

and given to the National Park of American Samoa 

and displayed in their visitor center. The anchor was 

lost in the September 2009 tsunami that destroyed 

the visitor’s center. 

In March 2011, 12 Manu’a community 

representatives, and 5 students and 5 teachers from 

Manu’a schools attended a trip to the Refuge. The 

purpose of the trip was documenting the oral history 

of Rose Atoll. It was sponsored by the IGC 

(consisting of the DMWR, the Service, ONMS, 

NMFS and ASDOC) and was funded by a grant 

from the NMFS to the DMWR. The SSI completed 

a report (entitled “Oral Traditions of Rose Atoll 

(Muliava)”), along with a bilingual brochure and DVD, to document the trip as well as the 

connections between the people of Manu’a and Rose Atoll (Muliava, Nu’u o Manu). 

The information generated from this trip will be used to produce EE and cultural interpretation 

materials for use by communities and outreach to the larger public. 

In February 2012, 3 archeologists (including lead archaeologist David Herdrich from ASHPO) 

conducted a 5-day survey of Rose Atoll on a Service-sponsored trip. This was the first in-depth 

archeology trip to Rose Atoll conducted. At the time of this writing their results are still being 

analyzed, which will be available to the public when completed. 

A canoe anchor that was found on Sand Island by 

David Herdrich, ASHPO, in 1990. NPS

Fallen monument (archaeological team visit with USFWS and NPS staff) and Navy survey marker (right photo). 

USFWS
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5-6 Chapter 5. Social and Economic Environment

5.2 Refuge Facilities 

Refuge facilities are usually structures that support both visitor services and biological management 

at a refuge. However, Rose Atoll NWR is closed to general public use and has no permanent 

infrastructure such as roads, fences, trails, etc. At one time, the Refuge did have a sign at Rose Island 

identifying the atoll as a NWR and being closed to visitors; however, due to weather conditions and 

storm events, it has since fallen into disrepair and is no longer on the island. 

Though the Refuge does not have facilities at the atoll, it does have office space co-located with the 

National Park of American Samoa in Tutuila and also contracts a boat for transportation to the atoll 

for management purposes. 

5.3 Public Use Overview 

The Refuge is closed to general public use to protect the sensitive habitats and wildlife at the atoll. Its 

remote location, logistical challenges, and safety issues also substantiate its closure to the general 

public. 

5.4 Wildlife-Dependent Public Uses 

The Improvement Act identified wildlife observation and photography, hunting and fishing, and EE 

and interpretation as wildlife-dependent, priority public uses for the Refuge System, when 

compatible. An SUP is required to enter the Refuge for any purpose. 

5.4.1 Hunting

The Refuge is not open for hunting due to the sensitive wildlife found at the atoll. 

5.4.2 Fishing

In the 1980s, the Refuge’s Public Use Policy permitted fishing in the Refuge as long as the fish were 

released or consumed within the Refuge (USFWS 1987). However, this policy was discontinued in 

the early 1990s. The Refuge continues to be closed for fishing due to the small size of the lagoon and 

its limited fish and invertebrate community. The ecological limits of these populations make them 

particularly vulnerable to fishing pressure. Closure to fishing also adheres to the Monument 

Proclamation (which directs us to prohibit commercial fishing in the Monument), meets the Refuge’s 

purposes, and fulfills the Governor of American Samoa’s support for a no-take area to protect the 

coral reef ecosystem. Fishing is offered in other parts of American Samoa. 

5.4.3 Wildlife Observation and Photography

The Refuge is not open to wildlife observation or photography and no SUPs have been issued in the 

past for this activity. Wildlife observation and photography opportunities are offered on the high 

islands of American Samoa (e.g., National Park of American Samoa). 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 5. Social and Economic Environment 5-7 

5.4.4 Environmental Education

During the 1980s and 1990s, field trips for students and teachers to the Refuge occurred. However, 

given the disturbance to wildlife, logistical difficulties, safety issues, and lack of available staff, such 

opportunities were discontinued and there is no EE currently offered at the Refuge. However, other 

types of EE about the Refuge are offered on Tutuila and the Manu’a Islands (see Chapter 2 regarding 

the future focus of EE on bringing the Refuge to the people, not bringing the people to the Refuge). 

5.4.5 Interpretation/Outreach

The Service maintains a website (http://www.fws.gov/roseatoll/) and we have given regular talks 

about Rose Atoll to students at the American Samoa Community College. Prior to the 2009 tsunami, 

there was interpretive information about Rose Atoll and the Refuge at the National Park of American 

Samoa visitor center. The Service is presently working with NPS to have displays again in their new 

visitor center. There is also an exhibit on Rose Atoll at the Tauese P.F. Sunia Ocean Center. 

5.4.6 Cultural Resources Interpretation

Currently no cultural resources interpretation is conducted. However, the March 2011 and February 

2012 trips identified in the previous section will provide information that can be used for these 

purposes in the future. 

5.5 Illegal Uses

Due to the remoteness of the Refuge, systematically documenting illegal use is challenging.

Documented cases between 1973-2005 (Wegmann and Holzwarth 2006) recorded two illegal 

incidents. Additionally, according to the annual law enforcement Refuge System reports, one 

incident of trespass was recorded in 2010. However, given accounts provided to Refuge staff and 

encounters during Refuge visits, it is known that recreational boaters and fishermen enter the Refuge 

illegally. In June 2009, Service staff were called upon to help rescue a grounded boat in the lagoon. 

On a September 2010 trip to Rose Atoll conducted by the Service and the DMWR, two private 

vessels expecting to enter the Refuge were turned away. Vessels over 50 feet are excluded from 

fishing within 50 nautical miles of Rose Atoll. NOAA NMFS established the final rule for fishing 

within the Monument in June 2013 and the Service is working with partners to develop enforcement 

options. 

The Service law enforcement issues on lands 

and waters of the Refuge are under the 

jurisdiction of the Refuge Zone Officer based in 

Honolulu. The role of this officer is to conduct 

and document law enforcement incidents and 

coordinate and/or meet with Refuge staff as 

well as law enforcement partners. Primary laws 

and regulations enforced include, but are not 

limited to the:

Yacht being towed out of the Refuge. Wally Thompson
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5-8 Chapter 5. Social and Economic Environment

• Administration Act;

• Lacey Act;

• Archaeological Resource Protection Act; 

• ESA; 

• MBTA; 

• MSFCMA; and

• Marine Mammal Protection Act.

Zone officers are also empowered to enforce all criminal laws and often partner with other law 

enforcement agencies. The USCG enforces natural resource laws by providing patrol and 

surveillance of the Refuge, both on-site and through remote sensing. The Refuge Zone Officer 

coordinates with the USCG on issues of trespass and illegal activities. 

5.6 Social/Economic Environment

5.6.1 Communities near Rose Atoll National Wildlife Refuge 

The nearest community to the Refuge is the Manu’a Islands, approximately 80 miles away. The next 

group of islands closest to the Refuge is Tutuila and Aunu’u, approximately 180 miles away. Tutuila 

is where the main population, government, and industries in American Samoa are located. 

5.6.2 Population, Housing, and Income

In 2010, the population of American Samoa was around 55,519. This represented a decrease of 3.1% 

from the 2000 Census population of 57,291. A majority of this population lives on Tutuila with only 

about 1,100 people living in the Manu’a Islands. In 2009, the median household income was $28,892 

(U.S. Census Bureau 2010). The total population of American Samoa is comprised of approximately 

93% native Pacific islanders, 4% Asian, 1% white, and 2% other ethnic origin. The median age is 23 

years (OIA 2012). For people on Ta’ū Village (Si’ufaga) and Faleasao (Leusoali’i), there was a high 

percentage of high school graduates or higher (70.5% and 56.8% respectively). These two villages 

also were overwhelmingly Samoan in terms of population composition (91.3% and 99.4% 

respectively) (U.S. Census Bureau 2003). 

Measuring economic welfare in American Samoa is challenging due to lack of data. It should also be 

noted that cost of living and income cannot be compared to the continental U.S. as American Samoa 

still maintains traditional lifestyles where subsistence living is a common way of life. Three common 

measures of economic welfare are the unemployment rate, per capita income, and gross domestic 

product per worker; however, there are almost no data on these measures. Based on a study that was 

conducted for the American Samoa Department of Commerce (McPhee et al. 2008), the 

unemployment rate in 2002 was in the vicinity of 7%, roughly one-half the rate in 1977, real per 

capita income rose at a 2.1% annual rate between 1977 and 2002, and nominal-dollar gross domestic 

product (GDP) per worker increased from $6,054 in 1977 to $27,048 in 2002. The study found that 

employment had doubled between 1977 and 2002, the unemployment rate had fallen, and per capita 

income rose by about 2%. 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 5. Social and Economic Environment 5-9 

5.6.3 Employment and Business

Major employers are the ASG and the fish processing industry, including fresh fish export and 

canning operations. The Chicken of the Sea tuna cannery closed in 2009, and in 2011, the StarKist 

cannery reduced its workforce due to changes in minimum wage standards (CIA Factbook). 

TriMarine, or Samoa Tuna Processors as known locally, took over Chicken of the Sea’s vacated 

facilities and started fresh fish export operations shortly thereafter. The American Samoa economy is 

not well diversified, leaving the Territory very dependent on the fish processing industries and 

Federal grants and aid. 

According to the U.S. Census Bureau’s 2007 Economic Census for Island Areas, the Manu’a District 

had 12 establishments with payroll which qualified for this census. A majority of this (8) was 

identified as retail trade. However, construction and educational, health, and social services were the 

industries which employed the largest percentage of workers in both Si’ufaga and Leusoali’i. About 

51.9% and 47.1% of Si’ufaga and Leusoali’i, respectively, were in the labor force and 14.3% of 

Si’ufaga people unemployed (there are no data for Leusoali’i) (U.S. Census Bureau 2003). 

Table 5-1. Employment and Labor Income 2002 

Source: McPhee et al. 2008
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

5-10 Chapter 5. Social and Economic Environment

Table 5-2. Economic Projections 2000-2015 

Note: Projections in the table above may have been affected by the 2008 economic downturn.

Source: McPhee et al. 2008

5.6.4 Refuge Impact on Local Economies

The Refuge has no substantial impact on the local economy. There is no visitation by the general 

public allowed to the Refuge, so impacts to the surrounding community economies does not exist as 

they do for other refuges. However, permitted activities, such as research, can contribute to the local 

economy via purchase of supplies, contracts for transportation and personnel, housing, food, etc. 

There is only one Refuge employee (a Refuge/Monument Manager) based out of Tutuila, so staff 

contribution to the local economy is negligible (e.g., personal expenditures such as rent, groceries, 

and work related expenditures such as operational supplies). Related Refuge personnel based in 

Honolulu, Hawai‘i, sometimes assist with Refuge management and can contribute to the local 

economy similar to research activities. The Fiscal Year (FY) 12 budget for the Refuge was $291,550. 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 5. Social and Economic Environment 5-11

5.6.5 Additional Economic Contributions

It is important to note that the economic value of the Refuge encompasses more than just the impacts 

on the regional economy. The Refuge also provides substantial nonmarket values (values for items 

not exchanged in established markets) that should also be considered. Examples include maintaining 

endangered species, preserving habitats, educating future generations, and adding stability to the 

ecosystem (Carver and Caudill 2007). According to a recent report, the total value of ecosystem 

services provided by natural habitats in the Refuge System in the contiguous states totaled $32.3 

billion per year, or $2,900 thousand per acre per year (Southwick Associates 2011). 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

5-12 Chapter 5. Social and Economic Environment
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix A. Species List A-1

Appendix A. Rose Atoll NWR Species Lists

A.1 Lists of Observed Species

Table A-1. Stony Coral List for Rose Atoll

Species* IUCN Status**

Acanthastrea brevis VU

Acanthastrea echinata LC

Acropora aspera VU

Acropora cerealis LC

Acropora digitifera NT

Acropora exquisita DD

Acropora gemmifera LC

Acropora globiceps VU

Acropora granulosa NT

Acropora humilis NT

Acropora kirstyae VU

Acropora latistella LC

Acropora longicyathus LC

Acropora loripes NT

Acropora nana NT

Acropora nasuta NT

Acropora paniculata VU

Acropora retusa VU

Acropora samoensis LC

Acropora selago NT

Acropora sp. not listed

Acropora squarrosa LC

Acropora tenuis NT

Acropora valida LC

Alveopora verrilliana VU

Astreopora cucullata VU

Astreopora listeri LC

Astreopora myriophthalma LC

Astreopora ocellata LC

Barabattoia laddi VU

Coeloseris mayeri LC

Coscinaraea columna LC

Coscinaraea exesa LC

Cycloseris fragilis LC

Cyphastrea chalcidicum LC

Cyphastrea decadia LC

Cyphastrea microphthalma LC

Cyphastrea serailia LC

Echinophyllia aspera LC

Echinopora lamellosa LC

Favia favus LC
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

A-2 Appendix A. Species List

Species* IUCN Status**

Favia matthaii NT

Favia maxima NT

Favia pallida LC

Favia rotumana LC

Favia speciosa LC

Favia stelligera NT

Favites flexuosa NT

Favites halicora NT

Favites russelli NT

Favites sp. not listed

Fungia concinna LC

Fungia granulosa LC

Fungia repanda LC

Fungia scutaria LC

Galaxea fascicularis NT

Goniastrea pectinata LC

Goniastrea retiformis LC

Goniopora somaliensis LC

Herpolitha limax LC

Hydnophora exesa NT

Isopora brueggemanni VU 

Isopora palifera NT

Leptastrea bewickensis NT

Leptastrea pruinosa LC

Leptastrea purpurea LC

Leptastrea sp. [small round calices] not listed

Leptoseris foliosa LC

Leptoseris incrustans VU

Leptoseris mycetoseroides LC

Leptoseris scabra LC

Leptoseris sp. [small round calices] not listed

Leptoseris yabei VU

Lobophyllia corymbosa LC

Lobophyllia hemprichii LC

Merulina ampliata LC

Millepora platyphylla*** LC

Montastrea annuligera NT

Montastrea curta LC

Montipora aequituberculata LC

Montipora angulata VU

Montipora calcarea VU

Montipora caliculata VU

Montipora danae LC

Montipora efflorescens NT

Montipora foliosa NT

Montipora foveolata NT

Montipora hoffmeisteri LC
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix A. Species List A-3

Species* IUCN Status**

Montipora incrassata NT

Montipora informis LC

Montipora lobulata VU

Montipora nodosa NT

Montipora peltiformis NT

Montipora sp. [bright blue] not listed

Montipora spumosa LC

Montipora tuberculosa LC

Montipora undata NT

Montipora venosa NT

Montipora verrucosa LC

Oulophyllia crispa NT

Oxypora glabra LC

Pavona chriquiensis LC

Pavona clavus LC

Pavona decussata VU

Pavona explanulata LC

Pavona maldivensis LC

Pavona minuta NT

Pavona varians LC

Pavona venosa VU

Platygyra carnosus NT

Platygyra contorta LC

Platygyra daedalea LC

Platygyra lamellina NT

Platygyra pini LC

Platygyra ryukyuensis NT

Plesiastrea versipora LC

Pocillopora brevicornis not listed

Pocillopora damicornis LC

Pocillopora eydouxi NT

Pocillopora meandrina LC

Pocillopora molokensis DD

Pocillopora verrucosa LC

Porites australiensis LC

Porites lichen LC

Porites lobata NT

Porites lutea LC

Porites rus LC

Porites solida LC

Porites superfusa not listed

Porites vaughani LC

Psammocora contigua NT

Psammocora haimeana LC

Psammocora nierstraszi LC

Psammocora profundacella LC

Scapophyllia cylindrica LC
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

A-4 Appendix A. Species List

Species* IUCN Status**

Stylaster cf. elegans*** not listed

Stylocoeniella armata LC

Stylocoeniella guentheri LC 

Stylophora pistillata NT

Symphyllia agaricia LC

Symphyllia recta LC

Turbinaria frondens LC

Turbinaria mesenterina VU

Turbinaria reniformis VU

Turbinaria stellulata VU

* The 19 species in bold were petitioned by the Center for Biological Diversity for listing under the U.S. 

Endangered Species. The NOAA NMFS found the 12 species underlined warrant listing as threatened.

** DD = Data Deficient, LC = Least Concern, NT = Near Threatened, and VU = Vulnerable.

***Hydrozoan coral. 

Sources: Kenyon et al. (2010, 2011), IUCN (2008).

Table A-2. Fish List for Rose Atoll

Scientific Name* Common Names Samoan Names Wass Habitats**

Abudefduf spp. Sergeant major

Acanthurus achilles Achilles tang CB, P

Acanthurus albipectoralis Whitefin surgeonfish

Acanthurus blochii Ringtail surgeonfish

Acanthurus glaucoparieus 

(or A.nigricauda?) CB

Acanthurus guttatus Whitespotted surgeonfish

Acanthurus lineatus Striped surgeonfish

Acanthurus mata CB, P

Acanthurus nigricans Whitecheek surgeonfish pone-i’usina

Acanthurus nigricauda Blackstreak surgeonfish pone-i’usina

Acanthurus nigrofuscus Brown surgeonfish ponepone CB

Acanthurus nigroris CB, RF, P

Acanthurus olivaceus Orangeband surgeonfish pone-apasama, 

afinamea RF

Acanthurus pyroferus Mimic surgeonfish pone-i’usama LF, P

Acanthurus thompsoni P

Acanthurus triostegus Convict tang manini CB, RF

Acanthurus xanthopterus Yellowfin surgeonfish

Adioryx microstomus CB

Adioryx spinifer CB, P

Adioryx tiere Lagoon

Aluterus scriptus Scrawled filefish

Amphiprion chrysopterus Reef front

Anampses twistii Yellowbreasted wrasse sugale-tatanu

Anthias lori Reef front

Anthias pascalus Reef front

Aphareus furca Smalltooth jobfish palu-aloalo

Aphareus furcatus P
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix A. Species List A-5

Scientific Name* Common Names Samoan Names Wass Habitats**

Apogon apogonides Goldbelly cardinalfish

Aprion virescens Green jobfish asoama, utu LF, P

Arothron meleagris Guineafowl pufferfish sue-puleuli (dark), suelega (yellow)

Balistapus undulatus Orange-lined triggerfish sumu-aimaunu CB, LF, P

Balistoides viridescens Reef front

Belonidae RF

Belonoperca chabanaudi Reef front

Bodianus anthioides Reef front

Bodianus axillaris

Bodianus diana

Bodianus loxozonus Blackfin hogfish

Bolbometopon muricatum Bumphead parrotfish

Caesio teres Yellow and 

bluebackfusilier

Calotomus carolinus Carolines parrotfish

Calotomus zonarchus Yellowbar parrot

Cantherhines dumerili Barred filefish pa’umalō

Canthidermis dumerili Yelloweye filefish Reef front

Canthigaster solandri Spotted toby sue-mimi CB

Canthigaster valentini Black-saddled toby sue-mu

Caracanthus maculatus Spotted croucher

Carangoides ferdau Blue trevally (Barred 

trevally)

Carangoides 

orthogrammus

Yellow-spotted trevally

(Island jack) 

Caranx ignoblis Giant trevally

Caranx lugubris Black trevally P

Caranx melampygus Bluefin trevally malauli-matalapo’a RF

Caranx sexfasciatus Bigeye trevally

Carcharhinus 

amblyrhynchos Gray reef shark RF

Carcharhinus 

melanopterus Blacktip reef shark apeape, maliealamata RF

Triaenodon obesus Whitetip reef shark RF, P

Centropyge bispinosus Two-spined angelfish 

(Dusky angelfish) tu’u’u-alomu CB

Centropyge flavissimus Lemonpeel angelfish tu’u’u-sama, tu’u’ulega CB, P

Centropyge heraldi CB

Centropyge loriculus Flame angelfish tu’u’u-tusiuli

Centropyge multifasciata Barred angelfish

Cephalopholis argus Peacock grouper gatala-uli CB, LF, P

Cephalopholis guttatus Reef front

Cephalopholis leopardus Leopard grouper

Cephalopholis miniata

Cephalopholis n. sp. Reef front
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

A-6 Appendix A. Species List

Scientific Name* Common Names Samoan Names Wass Habitats**

Cephalopholis spiloparaea Strawberry grouper

Cephalopholis urodelus CB, LF, P

Cephalopholis urodeta Flagtail grouper mata’ele

Chaetodon auriga Threadfin butterflyfish si’u, i’uusamasama CB, LF, P

Chaetodon bennetti Reef front

Chaetodon citrinellus Speckled butterflyfish tifitifi-moamanu CB, LF

Chaetodon ephippium Saddled butterflyfish tifitifi-tauli CB, LF, P

Chaetodon flavirostris Lagoon

Chaetodon kleinii

Chaetodon lineolatus Lined butterflyfish

Chaetodon lunula Raccoon butterflyfish tifitifi-laumea CB, LF, P

Chaetodon lunulatus Redfin butterflyfish tifitifi-manifi

Chaetodon mertensii Oval butterflyfish

Chaetodon ornatissimus Ornate butterflyfish

Chaetodon pelewensis Dot & dash butterflyfish tifitifi-tusiloloa CB RF LF P

Chaetodon 

quadrimaculatus Fourspot butterflyfish tifitifi-segasega CB, LF, P

Chaetodon reticulatus Reticulated butterflyfish tifitifi-maono CB, P

Chaetodon speculum

Chaetodon trifascialis LF

Chaetodon trifasciatus CB, LF

Chaetodon ulietensis Pacific double-saddle 

butterflyfish tifitifi-gutu’uli CB

Chaetodon unimaculatus LF

Chaetodon vagabundus Vagabond butterflyfish tifitifi-matapua’a CB

Chanos chanos Milkfish

Cheilinus chlorourus LF

Cheilinus oxycephalus LF

Cheilinus rhodochrous CB, LF

Cheilinus trilobatus LF

Cheilinus undulatus Maori wrasse

Cheilio inermis

Cheliodipterus 

quinquelineatus Fivelined cardinalfish fō CB

Chlorurus frontalis Tan-faced parrotfish 

(Reefcrest parrotfish)

Chlorurus japanensis Japanese parrotfish fuga-si’umū (IP), laeaulusama (TP)

Chlorurus microrhinos Steephead parrotfish laea (sm), ulumato 

(med), galo (lg)

Chlorurus sordidus Bullethead parrotfish fuga-gutumū (IP), 

fugausi-tuavela (TP) 

Chromis acares Midget chromis tu’u’u-fō

Chromis agilis Reef chromis 

(Agile chromis)

Chromis caerulea RF, LF, P
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix A. Species List A-7

Scientific Name* Common Names Samoan Names Wass Habitats**

Chromis iomelas Pacific half-and-half 

chromis tu’u’u-i’usina CB, P

Chromis margaritifer Bicolor chromis tu’u’u-I’usina P

Chromis vanderbilti Vanderbilt’s chromis Tu’u’u-fō

Chromis viridis Blue-green chromis i’alanumoana, tu’u’usegasega

Chromis xanthura Pale-tail chromis

Chrysiptera biocellata Twospot demoiselle

Chrysiptera brownriggii Surge damselfish

Chrysiptera glauca Gray demoiselle

Chrysiptera taupou South sea devil tu’u’u-mo’o, vaiulisama

Cirrhilabrus punctatus Dotted wrasse

Cirrhilabrus scottorum Redtailed wrasse 

(Scott’s wrasse)

Cirrhilabrus sp. RF, LF

Cirrhitus pinnulatus Stocky hawkfish

Cirripectes polyzona Barred blenny mano’o

Cirripectes stigmaticus Red-streaked blenny

Cirripectes variolosus Red-speckled blenny mano’o CB

Coris aygula Clown coris sugale-uluto’i RF

Coris gaimard Yellowtail coris sugale-mūmū, sugaletala’ula RF

Coryphopterus duospilus Twospot sand goby

Ctenochaetus cyanocheilus Bluelipped bristletooth

Ctenochaetus flavicauda Whitetail bristletooth

Ctenochaetus striatus Striped bristletooth 

(Lined bristletooth)

pone (adults), pala’ia, 

logoulia (schooling 

juv)

CB, LF, P

Ctenochaetus strigosus Spotted surgeonfish CB

Ctenogobiops pomastictus Gold-speckled 

shrimpgoby

Dascyllus aruanus Humbug dascyllus mamo RF, LF, P

Dascyllus reticulatus Reticulated dascyllus RF

Dascyllus trimaculatus Threespot dascyllus tu’u’u-pulelua

Diodon hystrix Porcupinefish tauta, tautu CB, P

Echeneis naucrates Sharksucker

Ecsenius fourmanoiri Fourmanoir’s blenny

Elagatis bipinnulata Rainbow runner

Epibulus insdiator Slingjaw wrasse

Epinephelus hexagonatus Honeycomb grouper

Epinephelus merra Dwarf spotted grouper gatala-aloalo, gatalapulepule CB, RF, LF

Epinephelus tauvina

Eviota guttata Spotted pygmy goby

Eviota punctulata Green bubblegoby

Fistularia commersonii Cornetfish taoto-ama, taotao
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

A-8 Appendix A. Species List

Scientific Name* Common Names Samoan Names Wass Habitats**

Flammeo opercularis Lagoon

Flammeo sammara CB

Forcipiger flavissimus Longnose butterflyfish 

(Forcepsfish) gutumanu CB, P

Forcipiger longirostris Big longnose butterflyfish gutumanu

Glyphidodontops cyaneus CB, RF, P

Gnathodentex 

aureolineatus

Yellowspot emperor 

(Striped large-eye bream) mumu, tolai CB, P

Gnatholepis cauerensis Shoulderspot goby

Gomphosus varius Bird wrasse gutusi’o, gutu’umi, 

sugale-lupe CB, LF, P

Gracila albomarginata Masked grouper

Gymnosarda unicolor Reef front

Gymnothorax javanicus Giant moray

Gymnothorax meleagris Turkey moray

Gymnothorax pictus Peppered moray

Halichoeres hortulanus Checkerboard wrasse sugale-a’au, sugalepagota, ifigi CB, RF

Halichoeres 

melasmapomus Reef front

Halichoeres ornatissimus Ornate wrasse

Halichoeres trimaculatus Threespot wrasse lape, sugale-pagota RF, LF

Hemigymnus fasciatus Barred thicklip sugale-gutumafia

Hemitaurichthys polylepis Reef front

Hemitaurichthys thompsoni

Gray butterflyfish 

(Thompson’s 

butterflyfish)

Heniochus chrysostomus Pennant bannerfish laulaufau-laumea

Heniochus monoceros Masked bannerfish

Heniochus varius

Kyphosus sp. Chub nanue

Labrichthys unilineatus

Labroides bicolor Bicolor cleaner wrasse sugale-i’usina CB, P

Labroides dimidatus Bluestreak cleaner wrasse sugale-mo’otai CB, LF, P

Labroides praetextatus Knife razorfish

Labroides rubrolabiatus Redlip cleaner wrasse CB, P

Labropsis sp. Reef front

Labropsis xanthonota

Wedgetail wrasse 

(Yellowback tubelip 

wrasse)

Lethrinus erythracanthus Yellowfin emperor

Lethrinus rubrioperculatus RF, LF, P

Lethrinus xanthochilus Yellowlip emperor

Lutjanus bohar Red snapper (Twinspot 

snapper) mū RF, P

Lutjanus fulvus Blacktail snapper tamala, tāiva CB, P

Lutjanus gibbus Humpback snapper mala’ī CB, P
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix A. Species List A-9

Scientific Name* Common Names Samoan Names Wass Habitats**

Lutjanus kasmira Bluestripe snapper savane CB, P

Lutjanus monostigmus Onespot snapper 

(Bluelined snapper) tāiva, feloitega CB

Macolor niger Reef front

Macolor spp. Black or Midnight snapper matala’oa

Malacanthus latovittatus Blue blanquilllo

Melichthys niger Black triggerfish sumu-uli

Melichthys vidua Pinktail triggerfish sumu-apa’apasina, 

Sumu-si’umumu CB, P

Monotaxis grandoculis Bigeye emperor 

(Humpnose bigeye bream) mū-matavaivai CB, LF, P

Mulloidichthys 

flavolineatus

Yellowstripe goatfish P

Mulloidichthys 

vanicolensis Yellowfin goatfish i’asina, vete, afulu, afolu CB, P

Myripristis berndti Big-scale soldierfish CB

Myripristis kuntee Epaulet soldierfish

Myriprstis vittata Whitetip soldierfish Reef front

Naso brevirostris Spotted unicornfish ume-ulutao

Naso hexacanthus Sleek unicornfish Reef front

Naso lituratus Orangespine unicornfish ili’ilia (sm) umelei 

(large) CB, LF

Naso tuberosus Humpnose unicornfish

Naso unicornis Bluespine unicornfish ume-isu P

Naso tonganus Bulbnose unicornfish

Naso vlamingii Bignose unicornfish ume-masimasi CB, LF, P

Nemateleotris magnifica Fire goby

Neocirrhites armatus Flame hawkfish Reef front

Neomyxus leuciscus Sharpnose mullet

Neoniphon opercularis Blackfin squirrelfish

Novaculichthys taeniourus Rockmover wrasse sugale-la’o (juv), 

sugale-tāili (adult), RF

Ostorhincus apogonides sugale-gasufi

Ostorhincus leslie New cardinalfish species

Ostracion meleagris RF, P

Oxycheilinus digrammus Cheeklined wrasse lalafi-gutu’umi

Oxycheilinus unifasciatus Ringtail wrasse lalafi

Paracirrhites arcatus Arceye hawkfish lausiva RF

Paracirrhites forsteri Freckled hawkfish lausiva

Paracirrhites hemistictus Halfspotted hawkfish

Parapercis 

cephalopunctata RF

Parapercis clathrata Latticed sandperch ta’oto

Parapercis millepunctata Black dotted sand perch

Parupeneus barberinus Dash-dot goatfish tusia RF, LF

Parupeneus bifasciatus Doublebar goatfish matūlau-moana RF

Parupeneus chryserydros RF, LF, P
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

A-10 Appendix A. Species List

Scientific Name* Common Names Samoan Names Wass Habitats**

Parupeneus cyclostomus Goldsaddle goatfish moana

Parupeneus insularis Twosaddle goatfish

Parupeneus multifasciatus Manybar goatfish

Parupeneus pleurostigma Sidespot goatfish matūlau-ilamutu RF, LF

Parupeneus trifasciatus RF, LF, P

Pempheris oualensis Copper sweeper

Plagiotremus tapeinosoma Piano fangblenny mano’o-to’ito’i CB

Plectroglyphidodon dickii Dick’s damselfish tu’u’u-i’usina P

Plectroglyphidodon 

johnstonianus Johnston damselfish tu’u’u-I’uuli

Plectroglyphidodon 

lacrymatus Jewel damselfish tu’u’u-lau, i’usamasama

Plectroglyphidodon 

phoenixensis Phoenix devil

Pomacentrus brachialis Charcoal damselfish tu’u’u-faga

Pomacentrus coelestis Neon damselfish tu’u’u-segasega

Pomacentrus vaiuli Princess damselfish tu’u’u-vaiuli CB, RF, P

Pomocanthus imperator Emperor angelfish

Pristiapogon exostigma Narrowstripe cardinalfish

Pristiapogon fraenatus Spurcheek cardinalfish

Pristiapogon kallopterus Iridescent cardinalfish

Pseudanthias pascalus Purple queen

Pseudobalistes 

flavimarginatus Yellowmargin triggerfish sumu-laulau (<20cm) Umu (>20cm) RF, LF, P

Pseudochelinus evanidus Disappearing wrasse 

(Striated wrasse) RF, LF

Pseudochelinus hexataenia Sixstripe wrasse sugale-manifi CB, LF, P

Pseudochelinus ocotaenia Eightstripe wrasse sugale-manifi

Pseudochelinus tetrataenia Fourstripe wrasse

Pseudodax moluccanus Chiseltooth wrasse

Ptereleotris evides Twotone dartfish 

(Blackfin dartfish) ma’ulu RF, LF, P

Ptereleotris microlepis Pearly dartfish

Ptereleotris zebra Zebra dartfish

Pterocaesio kohleri P

Pterocaesio tile Bluestreak fusilier P

Pterois antennata Antenna turkeyfish 

(Spotfin lionfish)

Pterois volitans Turkeyfish

Pygoplites diacanthus Regal angelfish tu’u’u-moana CB, P

Remora remora Remora

Rhinecanthus aculeatus Picasso triggerfish 

(Lagoon triggerfish) sumu-uo’uo RF, LF

Rhinecanthus rectangulus Wedgetail triggerfish sumu-aloalo

Sargocentron microstoma Smallmouth squirrelfish malau-tianiu
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix A. Species List A-11

Scientific Name* Common Names Samoan Names Wass Habitats**

Sargocentron spiniferum Sabre squirrelfish

tāmalau (<30cm), mumalau (>30cm), malautoa

Sargocentron tiere Tahitian squirrelfish

Saurida gracilis Slender lizardfish P

Scarus altipinnis

Scarus atropectoralis 

(S. caudofasicatus) Filament-fin parrotfish CB, P

Scarus festivus Festive parrotfish

Scarus forsteni Bluepatch parrotfish 

(Rainbow parrotfish)

Scarus frenatus Bridled parrotfish laea-mea (IP), laeasi’umoano (TP)

Scarus ghobban RF

Scarus gibbus RF

Scarus globiceps Violet-lined parrotfish 

(Roundhead parrotfish)

Scarus oviceps Dark capped parrotfish

Scarus psittacus Palenose parrotfish

fuga-matapua’a (juv),

fugausi-matapua’a 

(IP), laea-matapua’a 

(TP)

Scarus rubroviolaceus Redlip parrotfish laea-mea (IP), laeamala (TP)

Scarus schlegeli Yellowbar parrotfish fuga-matapua’a (IP), 

laea-tusi (TP) RF, LF, P

Scarus sordidus CB RF LF P

Scarus tricolor Reef front

Scarus xanthopleura Red parrotfish

Scomberoides lysan Doublespotted queenfish

Sphryaena helleri Heller’s barracuda

Sphyraena barracuda Barracuda sapatū

Sphyraena sp. Reef front

Sphyraena qenie Blackfin barracuda

Spratelloides sp. RF

Stegastes albifasciatus Whitebar gregory tu’u’u-pa, ulavapua

Stegastes nigricans Dusky gregory tu’u’u-moi

Stethojulis bandanensis Redshoulder wrasse lape-a’au

Sufflamen bursa Scythe triggerfish

(Lei triggerfish) sumu-pa’epa’e LF

Sufflamen chrysopterus Flagtail triggerfish sumu-gasemoana LF

Synodus variegatus Reef lizardfish ta’oto

Taeniura meyeni

Thalassoma 

amblycephalum

Bluehead wrasse 

(Two-tone wrasse) sugale-aloama CB

Thalassoma hardwicke Sixbar wrasse sugale-a’au, lapeele’ele CB, P

Thalassoma lutescens Sunset wrasse sugale-samasama LF, P
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

A-12 Appendix A. Species List

Scientific Name* Common Names Samoan Names Wass Habitats**

Thalassoma nigrofasciatum Blackbar wrasse

Thalassoma purpureum Surge wrasse uloulo-gatal (IP), 

patagaloa (TP) RF

Thalassoma 

quinquevittatum

Fivestripe wrasse 

(Redribbon wrasse) lape-moana CB, RF, P

Thalassoma trilobatum Christmas wrasse

Trachinotus baillonii Small-spotted dart 

(Small-spotted pompano)

Trimma sp. Goby

Valenciennea strigata Bluestreak goby mano’o-sina RF, LF

Zanclus cornutus Moorish idol pe’ape’a, laulaufau CB, LF, P

Zebrasoma rostratum Reef front

Zebrasoma scopas Brushtail tang pitopito, pe’ape’a CB, LF

Zebrasoma veliferum Pacific sailfin tang iliū CB, P

* Bolded font = fish species IUCN listed.

** Wass (1981) habitats: CB = coral blocks; RF = rubble flats; LF = lagoon floor; P = pinnacle.

Table A-3. Flora List for Rose Atoll

Species Common Name Samoan Name Invasive

Terrestrial:

Auricularia polytricha Wood fungus

Nephrolepis hirsutula Scaly sword-fern

Barringtonia asiatica Fish-poison tree Futu

Boerhavia repens Boerhavia, Alena Ufi’atuli

Calophyllum inophyllum Alexandrian laurel Fetau

Cenchrus echinatus Southern sandbur Invasive

Chloris barbata Swollen fingergrass Invasive

Cocos nucifera Coconut palm Niu Invasive

Cordia subcordata Cordia, Kou Taukanave

Gossypium hirsutum Polynesian cotton Vavae

Hibiscus tiliaceus Beach hibiscus Fau

Ipomoea macrantha Morning glory

Ipomoea pes-caprae Beach morning glory Fue moa

Pisonia grandis Pisonia Pu’a vai

Portulaca sp. Purslane Tamole

Suriana maritima Bay-cedar

Terminalia sp. Talie

Tournefortia argentea Tree heliotrope Tausuni

Marine:*

Bryoposis pennata

Halimeda taenicola

Halimeda fragilis

Halimeda micronesica

Halimeda minima

Halimeda opuntia

Ostreobium queketti
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix A. Species List A-13

Species Common Name Samoan Name Invasive

Valonia fastigiata

Microdictyon setchellianum

Dictyosphaeria versluysii

Caulerpa cupressoides (West)

Caulerpa cupressoides var. 

lycopodium

Lobophora variegata

Galaxaura filamentosa

Porolithon onkodes, P. craspedium, 

P. gardineri Crustose coralline algae

Jania spp. Coralline red algae

Peyssonnelia

Turf algae

Lyngbya, Oscillotoria, Symploca, 

Calothrix spp.

Cyanobacteria Can become 

invasive

*For the marine flora, the list is preliminary. 

Source: USFWS, CRED surveys (Brainard et al. 2008, Vroom, pers. comm. 2012, Burgett 2003).

Table A-4. Bird List for the Refuge

Species Common Name Samoan Name

Fregata ariel Lesser frigatebird Atafa

Fregata minor Great frigatebird Atafa

Puffinus pacificus Wedge-tailed shearwater Ta’i’o

Phaethon rubricauda Red-tailed tropicbird Tava’e’ula

Phaethon lepturus White-tailed tropicbird Tava’e

Sula sula Red-footed booby Fua’o

Sula leucogaster Brown booby Fua’o

Sula dactylatra Masked booby Fua’o

Egretta sacra Pacific reef heron Matu’u

Pluvialis fulva Pacific golden plover Tuli

Arenaria interpres Ruddy turnstone Tuli’alomalala

Numenius phaeopus Whimbrel Tuli

Numenius tahitiensis Bristle-thighed curlew Tuli’olovalu

Calidris alba Sanderling Tuli

Tringa incana Wandering tattler Tuli

Sterna sumatrana Black-naped tern Gogosina

Onychoprion lunatus Gray-backed tern Gogosina

Onychoprion fuscatus Sooty tern Gogosina, Gogo uli

Procelsterna cerulea Blue noddy Laia

Anous minutus Black noddy Gogo uli

Anous stolidus Brown noddy Gogo

Gygis alba White tern Manusina

Eudynamis taitensis Long-tailed cuckoo Aleva
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

A-14 Appendix A. Species List

Table A-5. Reptile List for the Refuge

Species* Common Name* Samoan 

Name

ESA Status

Chelonia mydas Green turtle I’a sa Threatened

Eretmochelys imbricata Hawksbill turtle Endangered

Gehyra oceanica Oceanic gecko

Lepidodactylus lugubris Mourning gecko

Table A-6. Selected Invertebrates Known to Occur at Rose Atoll

Species Common Name Samoan Name Introduced

Tridacna maxima Giant clam Faisua

Heterocentrotus, Diadema, 

Echinometra, Echinothrix, and

Echinostrephus spp.

Sea urchins Tuitui

Ocypoda spp. Ghost crabs

Coenobita perlatus and 

Coenobita brevimanus Land hermit crabs

Birgus latro Coconut crab

Pulvinaria urbicola Scale insect Urbicola soft 

scale

Introduced and 

invasive

Pheidole megacephala Big-headed ant Introduced and 

Invasive

Tetramorium bicarinatum Guinea ant, Tramp ant Introduced and 

Invasive
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix B. Appropriate Use Findings B-1

Appendix B. Appropriate Use Findings

B.1 Introduction

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 environmental education 

and interpretation) under the National Wildlife Refuge System Improvement Act of 1997 are 

generally exempt from appropriate use review. Other exempt uses include those where the Service 

does not have adequate jurisdiction to control the activity and refuge management activities. In 

essence, the Appropriate Refuge 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. During the CCP process the Refuge Manager evaluated all existing and 

proposed refuge uses at Rose Atoll National Wildlife Refuge using the following guidelines and 

criteria as outlined in the Appropriate Refuge Use policy:

• Do we have jurisdiction over the use?

• Does the use comply with applicable laws and regulations (Federal, State/Territorial, tribal 

and local)?

• Is the use consistent with applicable Executive orders and Department and Service policies?

• Is the use consistent with public safety?

• Is the use consistent with goals and objectives in an approved management plan or other 

document?

• Has an earlier documented analysis not denied the use or is this the first the use has been 

proposed?

• Is the use manageable within available budget and staff?

• Will this be manageable in the future within existing resources?

• Does the use contribute to the public’s understanding and appreciation of the refuge’s natural

or cultural resources, or is the use beneficial to the refuge’s natural or cultural resources?

• Can the use be accommodated without impairing existing wildlife-dependent recreational

uses or reducing the potential to provide quality (see section 1.6D, 603 FW 3, for 

description), compatible, wildlife-dependent recreation into the future?

Using this process and these criteria, and as documented on the following pages, the Refuge Manager

determined the following uses are appropriate:

Refuge Use – Rose Atoll NWR Appropriate?

Research, Survey, and Scientific Collections Yes
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

B-2 Appendix B. Appropriate Use Findings

Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

B-4 Appendix B. Appropriate Use Findings

Justification for “Appropriate” finding.

The use evaluated herein for appropriateness is more fully described and evaluated in the 

compatibility determination (CD) for this use and the documents referenced in that CD.

a. Do we have jurisdiction over the use?

The area for this use lies within Rose Atoll National Wildlife Refuge (Refuge). The Refuge lands and 

waters are administered by the U.S. Fish and Wildlife Service (Service), consistent with Title 50 of 

the Code of Federal Regulations (CFR). The Service has jurisdiction over public uses of the Refuge.

b. Does the use comply with applicable laws and regulations (Federal and Territorial)?

This use will comply with applicable laws and regulations. Permittees will be required to obtain 

necessary Territorial and Federal permits.

c. Is the use consistent with applicable Executive orders and Department and Service policies?

This use will be consistent with applicable Executive orders and U.S. Department of the Interior and 

Service policies, including the policies on Research and Management Studies (4 Refuge Manual 

[RM] 6) and Administration of Specialized Uses (5 RM 17).

d. Is the use consistent with public safety?

This use will be consistent with public safety. Permittees will be required to limit their use of the 

Refuge to specifically designated areas, and review and understand Refuge rules and regulations, and 

any hazardous conditions.

e. Is the use consistent with goals and objectives in an approved management plan or other 

document?

This use will not be inconsistent with any Refuge goals, and will usually support several goals. Each 

research proposal will need to be evaluated individually to determine the degree of support.

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 not denied this use.

g. Is the use manageable within available budget and staff?

Research, surveys, and scientific collections will be manageable within available budget and staff.

Stipulations contained within the compatibility determination will help ensure that administration of 

the uses remain manageable within available budget and staff.

h. Will this be manageable in the future within existing resources?

The activity will be manageable in the future with existing resources. Research, surveys, and 

collections will be conducted by the Service, partnering agencies, and other research institutions.
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix B. Appropriate Use Findings B-5

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 Service believes that wildlife and habitat conservation and management on the Refuge should be 

based upon statistically viable scientific research combined with long-term monitoring. The 

information gained through appropriate, compatible research on Refuge lands will be beneficial to 

the Refuge’s natural resources through application of this information into adaptive management 

strategies. The Refuge will also distribute any information gained to the public or incorporate into 

environmental education and interpretation programs and products, which will allow them to better 

understand and appreciate the Refuge resources and the need for protecting them.

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?

Research activities as described will not impair quality wildlife-dependent recreation should it be 

permitted in the future. 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

B-6 Appendix B. Appropriate Use Findings
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Appendix C. Compatibility Determinations C-1

Appendix C. Compatibility Determinations 

C.1 Introduction

The compatibility determinations (CDs) we developed during the Comprehensive Conservation Plan 

(CCP) planning process evaluate uses as projected to occur under Alternative B, the Preferred 

Alternative, in the Draft CCP/Environmental Assessment (EA) for the Rose Atoll National Wildlife 

Refuge (Refuge) (USFWS 2012). Alternative B has been carried forward as the management 

direction for the Refuge in this CCP. The evaluation of funds needed for management and 

implementation of each use is described in Appendix D, Implementation. Chapter 6 of the Draft 

CCP/EA also contains an analysis of the impacts of public uses to wildlife and habitats. That portion 

of the document is incorporated through reference into this set of CDs. 

C.2 Uses Evaluated At This Time

The following section includes full CDs for uses at the Refuge that are required to be evaluated at 

this time. According to Service policy, CDs are to be completed for all uses proposed under a CCP 

that have been determined to be appropriate. Existing wildlife-dependent recreational uses must also 

be re-evaluated and new CDs prepared during development of a CCP. According to the Service’s 

Compatibility policy, uses other than wildlife-dependent recreational uses are not explicitly required 

to be re-evaluated in concert with preparation of a CCP, unless conditions of the use have changed or 

unless significant new information relative to the use and its effects have become available or the 

existing CDs are more than 10 years old. However, the Service planning policy recommends 

preparing CDs for all individual uses, specific use programs, or groups of related uses associated 

with the proposed action. Accordingly, the following CDs are included in this document for public 

review. 

Refuge Use – Rose Atoll NWR Compatible Year Due for 

Re-evaluation

Research, Surveys, and Scientific Collections Yes 2023

Environmental Education Yes 2028

C.3 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 through a CD. 

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 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

C-2 Appendix C. Compatibility Determinations

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 a CD. 

Under the Compatibility policy, uses are defined as recreational, economic/commercial, or 

management use of a refuge by the public or a non-Refuge System entity. Uses generally providing 

an economic return (even if conducted for the purposes of habitat management) are also subject to 

CDs. The Service does not prepare CDs for uses when the Service does not have jurisdiction. For 

example, the Service may have limited jurisdiction over refuge areas where property rights are vested 

in others; where legally binding agreements exist; or where there are treaty rights held by tribes. In 

addition, aircraft overflights, emergency actions, some activities on navigable waters, and activities 

by other Federal agencies on “overlay refuges” are exempt from the CD process.

Compatibility regulations, required by the National Wildlife Refuge System Improvement Act of 

1997 (Improvement Act), were adopted by the Service in October 2000 (http://refuges.fws.gov/ 

policymakers/nwrpolicies.html). The regulations require that a use must be compatible with both the 

purpose(s) of the individual refuge and the Refuge System mission. This standard helps to ensure 

consistency in application across the Refuge System. The Improvement Act also requires that CDs be 

in writing and that the public have an opportunity to comment on most use evaluations. 

The Refuge System mission emphasizes that the needs of fish, wildlife, and plants must be of 

primary consideration. The Improvement Act defined a compatible use as one that “... in the sound 

professional judgment of the Director, will not materially interfere with or detract from the 

fulfillment of the mission of the System or the purposes of the Refuge.” Sound professional judgment 

is defined under the Improvement Act as “... a finding, determination, or decision, that is consistent 

with principles of sound fish and wildlife management and administration, available science and 

resources ...” Compatibility for priority 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 [Ruby Lake Refuge]). 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 Rose 

Atoll National Wildlife Refuge are based on the professional judgment of Refuge and planning 

personnel including observations of Refuge uses and reviews of relevant scientific literature. 

In July 2006, the Service published its Appropriate Refuge Uses policy (603 FW 1). Under this 

policy, most proposed uses must also undergo a review prior to compatibility. Uses excepted from 

the policy include wildlife-dependent recreational uses and uses under reserved rights (see policy for 

more detail). An Appropriate Refuge Uses Finding is included in Appendix B.
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Appendix C. Compatibility Determinations C-3

Compatibility Determination 

Use: Research, Surveys, and Scientific Collections. 

Refuge Name: Rose Atoll National Wildlife Refuge, Manu’a District, American Samoa.

Establishing and Acquisition Authority(ies): Fish and Wildlife Act of 1956. 

Refuge Purpose(s):

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

wildlife resources ...” 16 USC § 742f (a)(4); “... for the benefit of the United States Fish and 

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

the terms of any restrictive or affirmative covenant, or condition of servitude ...” 16 USC § 

742f(b)(1) (Fish and Wildlife Act of 1956, 16 U.S.C. §742(a)-754, as amended). 

National Wildlife Refuge System (Refuge System or NWRS) Mission: 

“The mission of the [National Wildlife Refuge] System is to administer a national network of lands 

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

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

generations of Americans” (National Wildlife Refuge System Improvement Act).

Other Management Direction: 

Presidential Proclamation 8337 

“... for the purposes of protecting the objects identified in the above preceding paragraphs ...” “For 

the purposes of protecting the objects identified above, the Secretaries of the Interior and Commerce, 

respectively, shall not allow or permit any appropriation, injury, destruction, or removal of any 

feature of this monument except as provided for by this proclamation or as otherwise provided for by 

law.”

Secretarial Order 3284 

“... For each of the areas subject to this delegation, the [Fish and Wildlife Service] Director shall 

provide for the proper care and management of the monument, including all objects of scientific and 

historic interest therein; the conservation of fish and wildlife; and the development of programs to 

assess and promote national and international monument-related scientific exploration and research.” 

(Section 4.a.(2). “... The Director shall manage the emergent and submerged lands and waters out to 

50 nautical miles from the mean low water line at Rose Atoll as the Rose Atoll Marine National 

Monument. The Director shall continue to manage the existing wildlife refuge at Rose Atoll within 

the boundaries set forth in the Notice of Establishment, 71 FR 13183 (April 5, 1974). Those areas 

beyond such mean low water line for which NOAA has the primary management responsibility for 

fishery-related activities are not included in the National Wildlife Refuge System.” (Section 4.c.). 

Description of Use(s): 

This use involves research, surveys, and scientific collections conducted by non-National Wildlife 

Refuge System (Refuge System) parties on Rose Atoll National Wildlife Refuge (NWR or Refuge). 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

C-4 Appendix C. Compatibility Determinations

Research refers to a planned, organized, and systematic investigation of a scientific nature. Such 

studies are designed to determine the cause(s) of observed biotic or abiotic phenomenon over a finite 

time period, where cause and effect relationships usually can be inferred through statistical analyses. 

Survey activities include scientific inventories and monitoring of fish, wildlife and plants, public use, 

and abiotic refuge resources (e.g., soils, water). 

Scientific collecting involves gathering of refuge natural resources or cultural artifacts for scientific 

purposes. Examples include collection of vegetation, marine invertebrates, and soils; contaminant 

sampling; adult and larval insect collection; and collection and curation of cultural resources. 

Refuge staff periodically receive requests from outside parties (e.g., universities, Territorial agencies, 

other Federal agencies, and nongovernmental organizations) to conduct research, surveys, and 

scientific collecting on Refuge lands and waters. These project requests can involve a wide range of 

natural and cultural resources as well as public-use management issues such as basic 

absence/presence surveys, collection of undescribed species for identification, study of habitat use 

and life-history requirements for specific species or species groups, evaluation of practical methods 

for habitat restoration, documenting extent and severity of environmental contaminants, testing 

techniques to control or eradicate pest species, measuring effects of climate change on environmental 

conditions and associated wildlife and habitat response, identification and analyses of paleontological 

specimens, documenting wilderness character, modeling wildlife populations, and assessing response 

of habitat and wildlife to disturbance from public uses. Projects may be species-specific, Refugespecific, or evaluate the relative contribution of Refuge lands and waters to larger landscapes (e.g., 

ecoregion, region, flyway, national, and international) issues and trends. 

The U.S. Fish and Wildlife Service’s (Service) Research and Management Studies (4 RM 6) and 

Appropriate Refuge Uses (603 FW 1) 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 refugespecific needs for resource management goals and objectives, where applicable, will be given a 

higher priority over other requests. Attached to this compatibility determination (CD) are examples 

of high-priority research, survey, and scientific collection topics for Rose Atoll NWR. 

This use is a privilege and not a right. It is not a wildlife-dependent recreational use. Research, 

surveys, and scientific collections on the Refuge will generally be authorized through individual 

Special Use Permits (SUPs) consistent with Refuge regulations (Title 50 of the Code of Federal 

Regulations [CFR] Parts 25- 37) and Service policy (5 Refuge Manual [RM] 17). Applicants will 

also be required to obtain any other relevant permits. Within the SUP, conditions will be clearly 

defined so as to protect and conserve the existing resources found within the Refuge. Before being 

allowed on the Refuge, this use will need to be found appropriate (603 FW 1) and then be determined 

compatible (603 FW 2). 

Research and exploration proposals may be for any time of the year and may be requested for any 

area of the Refuge. The Service, in consultation with the National Oceanic and Atmospheric 

Administration (NOAA) and others, as applicable, will evaluate each proposal and may put limits on 

the activities to ensure that negative impacts to resources are avoided or limited. 

Each research, survey, or scientific collections project will likely have different protocols and 

methods; therefore, each study necessitates its own scientific review. Each project will be carefully 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Appendix C. Compatibility Determinations C-5

reviewed to prevent any significant short-term, long-term, or cumulative impacts. New research or 

exploration requests will be evaluated by Service staff, applicable scientific partners at NOAA and 

American Samoa government, as well as other subject-matter experts if determined necessary by the 

Service. Evaluations and reviews will be conducted to determine if the species studied, methods 

used, or habitat type and locations affected may lead to undesirable cumulative impacts. Some of the 

standard and specific conditions are included in this CD under Stipulations Necessary to Ensure 

Compatibility. 

Collections of scientific specimens will be closely monitored and tracked as donations or loans to the 

permittee. Requirements for entering biological data or metadata into a national open-access database 

may be specified on SUPs. Donations or loans of collections will be managed in accordance with 

Title 50 of the CFR, sections 12.35-12.38, FWS Manual 701 FW 5, and Director’s Order No. 109, as 

amended. Permittees may use specimens collected under a permit, any components of any specimens 

(including natural organisms, enzymes, genetic materials or seeds), and research results derived from 

collected specimens for scientific or educational purposes only, and not for commercial purposes 

unless they have entered into a Cooperative Research and Development Agreement (CRADA) with 

the Service. The Service prohibits the sale of collected research specimens and other transfers to third 

parties must have Service authorization prior to any transfer. Permittees may be also required to 

transfer specimens to a museum or other curator, as identified by the Service.

Projects that involve public or private economic use of the natural resources of the Refuge will need 

to comply with relevant Federal regulations for such uses (50 CFR 29.1). In such cases, the Refuge 

will need to first determine that the use contributed to the achievement of Refuge purpose or the 

Refuge System mission prior to making a determination regarding the project’s compatibility. Public 

or private economic uses of specimens collected are not allowed in this CD. 

This use was proposed primarily because the collection and analysis of scientific data are extremely 

valuable to the Service for its ongoing management of the Refuge. The gathered information will 

also be used by other scientists, managers, decision-makers, and educators around the world. The 

published manuscripts from this research help to disseminate the Service mission and the 

significance of the Refuge resources to other researchers and the public. 

This programmatic CD has been developed and was made publicly available concurrent with the 

Draft Comprehensive Conservation Plan (CCP) and associated Environmental Assessment (EA) for 

Rose Atoll NWR. Much of the information and some of the analyses contained in this CD are 

addressed in greater detail in the Draft CCP/EA, which are incorporated through reference herein. 

Availability of Resources: 

Refuge responsibilities for research, surveys, and scientific collections by non-Refuge System 

entities are primarily limited to the following: review of proposals, preparation of an SUP(s) and 

reviewing other appropriate compliance documents submitted (pursuant to the National 

Environmental Policy Act, Endangered Species Act (ESA), National Historic Preservation Act, etc.), 

monitoring project implementation to ensure that impacts and conflicts remain within acceptable 

levels (remain compatible) over time, and reviewing scientific results. Additional administrative, 

logistical, and operational support could also be provided depending on each specific request. Law 

enforcement and dissemination of information about research and surveys in the Refuge are not 

included in these cost estimates. Estimated costs for one-time and annually re-occurring tasks by 

Refuge staff are determined on a project-by-project basis. Sufficient funding in the Refuge’s general 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

C-6 Appendix C. Compatibility Determinations

operating budget will need to be available to cover expenses for these projects. The terms and 

conditions for funding and staff support necessary to administer each project on the Refuge will be 

clearly stated in the SUP(s). 

The Refuge has the following staffing and funding to administratively support and monitor research, 

surveys, and scientific collections that are currently taking place on Rose Atoll NWR (see table 

below). Within the past 5 years, no more than 3 SUPs have been issued in a calendar year for Rose 

Atoll NWR. We will manage this use at the projected level with current capabilities of the Rose Atoll 

NWR and the Pacific Reefs NWR Complex. Any substantial increase in the number of projects will 

create a need for additional resources to satisfy administrative and monitoring needs to ensure the 

projects were implemented in a compatible manner. Any substantial additional costs above those 

itemized below could result in determining a project not compatible unless expenses were offset by 

the investigator, sponsoring organization, or other party. 

Following is an estimate of costs associated with administering this use on the Refuge. 

Category and Itemization One-time ($) Annual ($/yr) 1

Administration and management $7,000

Monitoring and Adaptive Management $6,800

Refuge overhead costs associated with the above-listed 

work2 $3,000

Offsetting revenues $16,800

1 Annual costs. Annual personnel costs include salary, locality pay and COLA, and benefits for a GS-12 Refuge manager, GS-12 

Refuge biologist, and GS-7 biological technician. 

2 Overhead costs include overhead expenses such as support personnel and do not include salary-related benefits. 

Anticipated Impacts of the Use(s): 

Use of the Refuge to conduct research, surveys, or scientific collecting will generally provide 

information of benefit to native fish, wildlife, plants, and their habitats or cultural resources. 

Scientific findings gained through these projects could provide important information regarding lifehistory needs of species and species groups as well as identify or refine management actions to 

achieve natural or cultural resource management objectives. Reducing uncertainty regarding wildlife 

and habitat responses to refuge management actions undertaken in order to achieve desired outcomes 

(objectives) is essential for adaptive management (522 Departmental Manual [DM] 1). 

Potentially, some projects’ methods could cause impacts to or conflict with Refuge-specific natural 

or cultural resources, other high-priority research, or Refuge management programs. In such cases, in 

order for the project to be determined compatible in the SUP review, it will need to be clearly 

demonstrated that the project’s scientific findings will contribute to Refuge management and that the 

project could not be conducted off-Refuge. The investigator(s) will need to identify approaches, 

methods, and strategies in advance to minimize or eliminate potential impacts and conflicts. If 

unacceptable impacts, including long-term and cumulative impacts, could not be avoided, then the 

project could not be determined compatible. 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Appendix C. Compatibility Determinations C-7

Refuge Goals and NWRS Mission 

It is likely that most proposed research, survey, or scientific collection projects will support one or 

more of the Refuge goals (particularly Goal 6), but each will need to be evaluated separately. 

Projects that were determined supportive of Refuge purposes, goals, and the Refuge System mission 

will have a greater chance of being found appropriate, determined compatible, and authorized for 

implementation. 

Fish, Wildlife, Plants, and Their Habitats 

Impacts will be project- and site-specific, and will vary depending upon the nature and scope of the 

field work. Data collection techniques will generally avoid or have minimal animal mortality or 

disturbance, habitat destruction, no introduction of contaminants, and no introduction of species. In 

contrast, projects involving the collection of biotic samples (plants or animals) or requiring intensive 

ground-based data or sample collection will at least have short-term, localized impacts. 

Disturbance to seabirds will likely be one of the greatest wildlife effects caused by terrestrial and 

nearshore research, surveys, and scientific collections. When birds are breeding they are all more 

vulnerable to disturbance. Flushing birds or even raising their alert levels creates stress and requires 

animals to expend energy that would otherwise be invested in essential life-history activities such as 

foraging, mating, nesting, brood-rearing, and predator avoidance. Disturbance can cause nest 

desertion; affect survival of individual birds, eggs, nestlings, or broods; and alter behavior of 

nonbreeding birds. 

Sea turtles that have come ashore to dig nests and lay eggs are highly focused on their reproductive 

objective. Turtles are easily disturbed during the early stages of the nesting process. Hatchlings may 

have difficulty emerging from the nest if the overlying sand has been compacted by human trampling 

and activities that introduce artificial light into the environment such as camping may disorient them 

on their way to the water. Disturbance and physical damage to fish, marine invertebrates, and corals 

may result during snorkeling, swimming, or diving activities. 

Field research could also cause trampling of native plants and benthic marine biota, erosion, and 

introduction or spread of exotic species, including microbes, invertebrates, terrestrial plants, algae, 

and other pest species. All of these impacts could adversely affect native fish, wildlife, plants, and 

their habitats. 

Improper boat operation could result in localized impacts to the coral reef from anchoring, touching, 

or other avoidable physical disturbance to the benthos including coral and crustose coralline algae. 

Lights on vessels working or transiting near the island at night may cause collisions with the vessel 

by birds returing to or leaving the island. 

Spread of nonnative or pest plants, invertebrates, or pathogens is possible from ground disturbance 

and transportation of project equipment and personnel. These effects will be minimized or eliminated 

by requiring proper cleaning of investigator equipment and adherence to quarantine protocols for 

clothing and camping gear and supplies. Restoration or mitigation plans in place and regular 

surveillance for new invasions will minimize damage from accidental introductions. 

Increased use of waters also increases the potential for introductions of nonnative species and 

interactions (some negative) by boats or snorkelers/divers with sea turtles, fish, cetaceans, and live 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

C-8 Appendix C. Compatibility Determinations

corals. One accidental introduction of a nonnative species on a boat or dive equipment could 

devastate the Refuge. Groundings by inappropriate boat operation could cause physical damage and 

introduce elements to enhance the spread of invasive species, such as was the case with the Jin 

Shiang Fa. 

There also could be localized and temporary effects from collecting of soil, plant, and algal samples, 

or trapping, handling, or collection of fish and wildlife. Impacts could also occur from infrastructure 

necessary to support a project (e.g., permanent transects or plot markers, exclosure devices). 

All of these impacts could adversely affect native fish, wildlife, plants, and their habitats. Increased 

activity increases risk of adverse impacts also. Individual circumstances associated with specific 

studies will determine the degree of actual effects upon reproduction, survival of individuals, and 

diversity and abundance of native species (community health). 

However, given the experience of staff with similar research projects conducted at the Refuge and 

other refuge atolls it is anticipated that these impacts can be avoided altogether or minimized. 

Examples includes avoiding nesting areas, minimizing lights used at night, Refuge-authorized 

personnel accompanying researchers and educating them on minimizing such impacts, requiring 

existing biosecurity protocols be followed, live-boating (i.e. having someone tending the boat instead 

of anchoring), using a diver to hand-place the anchor, using a diver to clear the anchor from the 

bottom before it is hauled up, and frequently checking the position of the boat for drift or anchor 

drag. 

Public Review and Comment: 

Public availability of this CD was widely announced together with announcement of the availability 

of the Refuge’s Draft CCP/EA. The review and comment period was also the same as for the Draft 

CCP/EA. Appendix J of the CCP contains a summary of the comments and Service responses. 

Determination: (check one below) 

 Use is Not Compatible 

 X Use is Compatible with following Stipulations 

Stipulations Necessary to Ensure Compatibility: 

Permission to use the Refuge for research, surveys, or scientific collections will be officially 

authorized through issuance of an SUP. Generally, SUPs may only be issued on a year-to-year basis. 

The SUP will cover use by a specified individual or organization and may not be assigned or subpermitted to others. These permits may stipulate more detailed access restrictions and regulations to 

protect wildlife or Refuge integrity from anticipated site-specific negative effects caused by the 

research project. At the discretion of the Refuge Manager, Refuge-approved staff may be assigned to 

accompany researchers. 

Prior to potential SUP renewal, Refuge staff will communicate with researchers to share new 

information, discuss results of monitoring, review compliance with SUP conditions, and address 

other issues. Other meetings will be scheduled as needed. 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Appendix C. Compatibility Determinations C-9

The Refuge staff will supply researchers with information about the Refuge; its purposes and goals; 

natural and cultural resources of concern; rules and regulations; and any hazardous conditions. 

Researchers are responsible for reviewing and understanding this information and ensuring that any 

associates entering the Refuge also received, reviewed, understood, and complied with this 

information. 

General 

1. In addition to the stipulations listed here, the general SUP conditions and requirements, and the 

special SUP conditions, researchers and their colleagues are required to comply with Refuge 

System-related and other applicable laws, regulations, and policies including “Prohibited Acts” 

listed in Title 50 of the CFR 27. 

2. Only activities specifically authorized in an SUP will be permitted. Other activities are 

prohibited, for example (but not limited to): 

a. Rose Atoll NWR is closed to general public use, so the SUP will include maps clearly 

depicting the areas researchers are authorized to access and use, including the Refuge entry 

point(s). Permittees are prohibited from straying outside the areas depicted on the maps. 

b. Researchers are prohibited from constructing new or maintaining existing structures on the 

Refuge without specific, prior written approval of the Refuge Manager. 

c. Consistent with Service policy regarding management of non-hazardous solid waste on 

refuges (561 FW 5), permittees are prohibited from littering, dumping refuse, abandoning 

equipment or materials, or otherwise discarding any items on the Refuge. 

d. Unless it was an element included in their approved project proposal, researchers and their 

colleagues are prohibited from collecting and removing any archaeological or historic 

artifacts, abiotic or biological specimens or samples, or mementos from the Refuge. 

3. Researchers will adhere to best management practices to minimize wildlife disturbance while at 

the Refuge as identified by the Refuge Manager through their SUP. 

4. No changes may be made to any of these stipulations without specific, prior written approval of 

the Refuge Manager. 

Specific Terms and Conditions (include but are not limited to): 

1. All scientific specimens are the property of the Service and collections are required to comply 

with Service regulations and policy as donations or loans to the permittee. Donations or loans of 

collected specimens will be managed in accordance with Title 50 of the CFR, sections 12.35-

12.38, FWS Manual 701 FW 5, Director’s Order No. 109 (as amended), and any other applicable 

Service or Department of the Interior regulation or guidance. Collections shall not be shared or 

distributed beyond the permittee without the expressed permission of the Service. Any loan 

remains the property of the Service and the Service may require its return at any time. The 

Service reserves the right to require the permittee to enter specimen data and metadata into a 

national, open-access database. 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

C-10 Appendix C. Compatibility Determinations

2. All research permit holders will be required to submit an annual report to the Refuge Manager 

that summarizes their activities for a given year and a final report when the project is completed. 

The report will include at a minimum the following: study title, SUP number, fiscal year, 

progress, important findings, and problems encountered, proposed resolution to problems, 

disposition of any collected samples, preparer, and date prepared. Final project reports are due in 

January following at least 1 year after expiration of the SUP. 

3. All publications and products derived from the SUP will appropriately acknowledge the Service 

and state the activities were conducted under Refuge System SUP. Appropriate 

acknowledgement should also be given to NOAA when applicable. All reports, publications, or 

products will reference the Rose Atoll National Wildlife Refuge and Rose Atoll Marine National 

Monument. 

4. Researchers are required to provide Refuge staff with the following: 

a. An opportunity to review and comment on draft manuscripts prior to their submittal to a 

scientific journal for consideration for publication. 

b. At least two copies (reprints) of all publications articles, or other product created as a result 

of information gained or work completed under this permit, including materials generated at 

any time in the future following expiration of this permit. 

c. At the conclusion of the project, raw data (preferably in an electronic database format) or 

unrestricted access to the raw data upon request. 

5. Upon completion of the project or annually, the researcher is required to remove all equipment 

and physical markers (unless required for long-term projects) and restore sites to the Refuge 

Manager’s satisfaction. The SUP will specify conditions for removal and clean up. 

6. The SUP does not remove the permittees’ obligation to obtain all additional permits, 

authorizations, or regulatory compliance, including but not limited to local, Territorial, and 

Federal permits for collections, or ESA or MMPA consultation. 

7. To reduce impacts, the minimum number of samples (e.g., water, soils, vegetative litter, plants, 

macroinvertebrates, vertebrates, and artifacts) adequate for addressing the question in a credible 

manner will be collected for identification or experimentation. 

8. Researchers and related crew practice rigorous light control to avoid impacts to wildlife. 

9. If the proposed research methods will materially impact, or cause appropriation, injury, 

destruction, or removal of any Refuge resource, the permittee must identify the issues in advance. 

Highly intrusive or manipulative research is generally not permitted. As much of this work will 

be experimental due to the extreme environment, any unanticipated disturbance will immediately 

be brought to the attention of the Refuge Manager. 

10. Where possible, researchers will be required to coordinate and share collections with other 

investigators. This could reduce sampling needed for multiple projects and any associated 

mortality and disturbance. For example, if one investigator collected fish for a diet study and 

another researcher was examining otoliths, then it could be possible to accomplish sampling for 

both projects with one collection effort. 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Appendix C. Compatibility Determinations C-11

11. To minimize the introduction of pests, sampling equipment as well as researcher’s clothing and 

vehicles (e.g., boats) need to be thoroughly cleaned (free of marine fouling organisms, dirt and 

plant material) before being used on the Refuge. Depending on the project, quarantine protocols 

may be necessary. 

12. Researchers are required to secure approval from the Service prior to use of any pesticides 

(including uses of herbicides, fungicides, and insecticides) on the Refuge. This will involve 

researchers submitting to the Refuge Manager a completed Pesticide Use Proposal (PUP) for 

each proposed pesticide use. These PUPs will need to be submitted at least 90 days prior to 

proposed use of the pesticide to allow adequate time for evaluation and processing. 

13. At any time, Refuge staff may accompany researchers in the field, with the researcher required to 

provide transportation unless other arrangements are made prior to the trip. The Refuge Manager 

or designee can suspend or modify an SUP or its conditions or terminate research, surveys, or 

collections that are already permitted and in progress should unacceptable, unforeseen, or 

unexpected impacts or issues arise or be noted. 

14. Violation of any of these stipulations could result in temporary or permanent withdrawal of 

official permission to continue research, surveys, or scientific collections on the Refuge. The 

SUP could be revoked by the Refuge Manager immediately for non-compliance with these 

stipulations. 

Monitoring, Adaptive Management, and Enforcement 

1. The Refuge has the right to add to or otherwise modify the stipulations listed herein in order to 

ensure the continued compatibility of this use. 

2. Failure to complete administrative and reporting requirements may be used as a reason to deny 

future permit requests. 

Justification: 

Research, surveys, and scientific collections on refuges can be inherently valuable to the Service 

because they expand scientific information available for resource management decisions about fish, 

wildlife, plants, and their habitats; cultural resources; or public use. In many cases, if it were not for 

the refuge staff providing access to refuge lands and waters along with some support, the project 

would never occur and less scientific information would be available to aid the Service in managing 

and conserving refuge resources. 

By allowing the use to occur under the stipulations described above, it is anticipated that wildlife 

which could be disturbed by this use will 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; cultural resources; and public use. Where this was not the case, the proposed project 

will likely not be compatible and will not be authorized for implementation. The Refuge staff will 

also monitor habitat quantity and quality, wildlife use and productivity, water quality, cultural 

resources, and other relevant endpoints to determine if stipulations associated with research, surveys, 

and scientific collections were resulting in expected and desirable outcomes. In consultation with 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

C-12 Appendix C. Compatibility Determinations

researchers, the Refuge staff will apply adaptive management principles to modify stipulations or 

adjust objectives, as necessary, to achieve desirable results. 

As a result, potential research, surveys, and scientific collections, consistent with the stipulations 

described herein, will not materially interfere with or detract from maintenance of the Refuge’s 

biological integrity, diversity, and environmental health; fulfillment of the Rose Atoll NWR 

purposes; or the Refuge System mission. 

Mandatory 10- or 15-Year Re-evaluation Date: 

 Mandatory 15-year reevaluation date (for wildlife-dependent public uses) 

 2023 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 

 X Environmental Assessment and Finding of No Significant Impact 

 Environmental Impact Statement and Record of Decision 

This CD has been developed and issued concurrent with the Final CCP for Rose Atoll NWR. 

Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

C-14 Appendix C. Compatibility Determinations

References Used and Cited, and Glossary of Acronyms and Terms: 

Adaptive Management (522 DM 1). 

Administration of Specialized Uses (5 RM 17). 

Appropriate Refuge Uses (603 FW 1). 

National Historic Preservation Act of 1966, as amended (16 U.S.C. 470).

National Wildlife Refuge System Administration Act of 1966, as amended (16 U.S.C. 668dd-668ee). 

National Environmental Policy Act of 1969, as amended (42 U.S.C. 4321-4347). 

Prohibited Acts (50 CFR 27). 

Refuge Compatibility (603 FW 2). 

Solid Waste (Nonhazardous) (561 FW 5). 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Appendix C. Compatibility Determinations C-15

High-Priority Research, Surveys, and Scientific Collections 

Following are examples of high-priority research, survey, and scientific collection topics for Rose 

Atoll NWR. They are not listed in priority order. 

Work with partners to deploy an Ecological Acoustic Recorder (EAR) in the ava to collect biological data 

that may improve monitoring of behavior and abundance of marine organisms

Within 5 years, begin to monitor climate change variables including sea level, temperature

(air/water/substrate), water quality (pH, conductivity, dissolved oxygen, nitrogen, photosynthetically 

available light (PAR), phosphorus, iron) and the frequency and duration of extreme storm events and 

biological responses (phenological, developmental, physiological)

Work with partners to monitor status and trends of focal communities (hard corals, algae), including the 

incidence and severity of coral and algal disease and bleaching

Within 5 years, monitor the growth and survival rate of coral colonies at different depths

Work with partners to conduct REA to document habitat associations and species distribution, density, 

and diversity in marine habitats 

Work with NOAA’s CRED and other partners to collect oceanographic and water quality data in order to 

track changes that could affect the reef or wildlife 

Within 5 years, develop and implement monitoring protocols to track populations of focal lagoon species 

including fish, corals, faisua, other invertebrates, and marine pests to determine abundance, density, and 

biomass of each at selected sites 

Work with partners to collect bathymetry data every 10 years in order to document changes in the lagoon, 

reef, or ava that could affect hydrography or habitat characteristics 

Within 5 years, develop and implement monitoring protocols to track abundance and distribution of focal 

perimeter reef species including eels and urchins to determine abundance, density, and biomass of each at 

selected sites 

Continue monitoring abundance and distribution of the cyanobacterial community which became 

dominant on a section of the southwest arm of the atoll due to elevated iron levels following a 1993 

shipwreck 

Monitor benthic succession of the reef which was damaged due to the 1993 shipwreck 

Within 5 years, work with partners to develop and implement reef monitoring program, including rate of 

growth, elevation change, chemical composition, and other variables related to reef growth and the atoll’s 

ability to maintain itself in an anticipated environment of climate change and ocean acidification 

Within 5 years, work with partners to monitor water flow rate and direction in the ava using archival 

pressure and flow rate instruments that can be downloaded at every visit in order to document any 

changes in flow through the ava 

Within 5 years, develop and implement monitoring protocol to track abundance and biomass of fish, 

including predatory and prey fish species, around the opening of the ava to detect any changes in structure 

or function of this important geological feature for large predators in the Refuge 

Within 2 years, working with NOAA/NMFS and other partners, develop and implement monitoring 

protocol to track turtle abundance and movements using field counts, tagging, a remote camera system,

and satellite telemetry 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

C-16 Appendix C. Compatibility Determinations

Within 2 years, use GPS to map the perimeter of the islands at high and low tide on each visit to the 

Refuge and obtain any available satellite imagery for incorporation into GIS in order to document 

changes in island size and location

Monitor survivorship, growth, and maturation of outplanted tamole

Within 2 years, prepare and implement a monitoring plan and rapid response program for terrestrial 

nonnative species and respond immediately if detected 

Within 2 years, review existing vegetation community distribution data and develop GIS database of 

terrestrial and marine habitats and update them regularly

Within 4 years, review available vegetation data and develop and implement a monitoring protocol to 

track changes in numbers, cover, and basal area of different species 

Within 3 years, develop and implement a monitoring protocol to track seabird abundance, nesting rates, 

and feeding territories. Include remote camera observations to improve future monitoring efforts 

Within 10 years, characterize nutrient budgets and dynamics at Rose Atoll and evaluate them relative to 

data from other similar reef sites to identify possible stressors and the positive effects of healthy seabird 

colonies adjacent to living reefs 

Within 5 years, work with universities and other partners to evaluate the geomorphology, hydrology, and 

sediment budget of Rose Atoll to understand the processes that have maintained the islands as dynamic 

units 

Within 10 years, investigate the ecological relationships between marine gastropods such as turban shells 

(Turbo spp.) and land hermit crabs (Coenobita perlatus and C. brevimanus). Evaluate factors affecting 

crab populations, including observed reduction in availability of shells to crabs, at the Refuge and what 

management may improve mollusk shell availability to the Coenobita spp. which are important 

scavengers and herbivores on both islands 

Within 3 years, work with universities and other partners to investigate composition and structure of 

terrestrial communities on Rose Island prior to the introduction of rats to inform ecological restoration 

activities 

Work with universities and other partners to investigate food habits of seabirds breeding at Rose Atoll 

using stable isotopes and stomach samples

Work with universities and other partners to correlate reproductive performance indicators and breeding 

chronology variation with oceanographic conditions and location of migratory fish schools relative to the 

atoll

Conduct study to determine if aquifer exists at Rose Atoll. If found, within 5 years, begin monitoring the 

lens to document extent and changes
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Appendix C. Compatibility Determinations C-17

Compatibility Determination 

Use: Environmental Education. 

Refuge Name: Rose Atoll National Wildlife Refuge, Manu’a District, American Samoa.

Establishing and Acquisition Authority(ies): Fish and Wildlife Act of 1956. 

Refuge Purpose(s):

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

wildlife resources ...” 16 USC § 742f(a)(4); “... for the benefit of the United States Fish and 

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

the terms of any restrictive or affirmative covenant, or condition of servitude ...” 16 USC § 

742f(b)(1) (Fish and Wildlife Act of 1956, 16 U.S.C. §742(a)-754, as amended). 

National Wildlife Refuge System (Refuge System or NWRS) Mission: 

“The mission of the [National Wildlife Refuge] System is to administer a national network of lands 

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

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

generations of Americans” (National Wildlife Refuge System Improvement Act).

Other Management Direction: 

Presidential Proclamation 8337 

“... for the purposes of protecting the objects identified in the above preceding paragraphs ...” “For 

the purposes of protecting the objects identified above, the Secretaries of the Interior and Commerce, 

respectively, shall not allow or permit any appropriation, injury, destruction, or removal of any 

feature of this monument except as provided for by this proclamation or as otherwise provided for by 

law.”

Secretarial Order 3284 

“... For each of the areas subject to this delegation, the [Fish and Wildlife Service] Director shall 

provide for the proper care and management of the monument, including all objects of scientific and 

historic interest therein; the conservation of fish and wildlife; and the development of programs to 

assess and promote national and international monument-related scientific exploration and research.” 

(Section 4.a.(2). “... The Director shall manage the emergent and submerged lands and waters out to 

50 nautical miles from the mean low water line at Rose Atoll as the Rose Atoll Marine National 

Monument. The Director shall continue to manage the existing wildlife refuge at Rose Atoll within 

the boundaries set forth in the Notice of Establishment, 71 FR 13183 (April 5, 1974). Those areas 

beyond such mean low water line for which NOAA has the primary management responsibility for 

fishery-related activities are not included in the National Wildlife Refuge System.” (Section 4.c). 

Description of Use(s): 

Environmental education (EE) is a wildlife-dependent general public use and is to be given special 

consideration in refuge planning and management when compatible. When determined compatible 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

C-18 Appendix C. Compatibility Determinations

on a refuge-specific basis, a wildlife-dependent use becomes a priority public use for that refuge and 

is to be facilitated (see 16 U.S.C. 668dd-668ee). 

Service policy defines EE to be “a process designed to teach citizens and visitors the history and 

importance of conservation and the biological and the scientific knowledge of our ... natural 

resources. Through this process ... [the Service] ... can help develop a citizenry that has the 

awareness, knowledge, attitudes, skills, motivation, and commitment to work cooperatively towards 

the conservation of our ... environmental resources. Environmental education within the Refuge 

System incorporates on-site, off-site, and distance learning materials, activities, programs, and 

products that address the audience’s course of study, refuge purpose(s), physical attributes, 

ecosystem dynamics, conservation strategies, and the Refuge System mission” (605 Fish and 

Wildlife [FW] 6). 

Environmental education is a formal, structured program that incorporates measurable learning 

objectives and uses audience-appropriate curricula to satisfy Territorial or other standards. 

Environmental education activities can be provided by Refuge personnel, a volunteer(s), or other 

Service-authorized agent(s); or through partnerships with groups that share similar goals (e.g., a new 

Refuge friends group, partners, or others). For purposes of this CD, EE includes education regarding 

natural, historic, and cultural resources and values. 

Although there were some activities in the past, the Service currently offers no EE program for the 

Rose Atoll NWR. Under the CCP’s management direction, the Service will provide EE, with an 

objective of eventually serving EE once every 3 years for on-site opportunities in small groups of 

fewer than 10 people. These visits will be led by a Refuge-authorized agent with the stipulations 

identified to ensure compatibility with this activity. Other EE opportunities will be provided off-site 

in the form of materials developed, classroom instruction and curriculum, student intern programs, 

satellite transmissions to schools, and partnering. 

This CD has been developed and made publicly available concurrent with the Draft CCP and 

associated EA for Rose Atoll NWR. Much of the information and some of the analyses contained in 

this CD are addressed in greater detail in the Draft CCP/EA, which are incorporated through 

reference herein. 

Availability of Resources: 

Following is an estimate of costs associated with administering this use on the Refuge. 

Tasks Estimated Costs 

per Year1

Oversight of program by Refuge Manager GS-12 (5%); $5,870

Biological monitoring by Biologist GS-12 (1%) $1,260

Supplies and equipment $500

Refuge overhead costs associated with the above-listed work2$1,000

Total Costs $8,630

1 Annual costs. Annual personnel costs include salary, locality pay and COLA, and benefits. 

2 Overhead costs include overhead expenses such as support personnel and do not include salary-related benefits. 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Appendix C. Compatibility Determinations C-19

The Refuge does not currently have adequate budget and staff to support the annual costs associated 

with the full planned EE program for the Refuge. Smaller components of it are feasible with the 

existing budget, however it will be necessary to recruit, train, and utilize volunteers, an intern, or 

other partners to fully support all the planned activities as identified in the CCP.

Additional funding for specialized telepresence technology will need to be made available (either 

through the Service budget system or from an outside source) in order to allow this use to occur in a 

compatible manner. Should internal funding not materialize, the Service will seek outside funding 

(e.g., from other agency partners or private conservation organizations). 

Transportation costs to reach the Refuge, costs of upkeep and replacement of Refuge special 

equipment, and costs of activities on the Refuge are paid for by the participant or covered through 

grants or partners. 

Anticipated Impacts of the Use(s): 

Refuge Goals and Refuge System Mission 

Environmental education will support Refuge Goal 7. 

Fish, Wildlife, Plants, and Their Habitats 

The Refuge purpose is for the development, advancement, management, conservation, and protection 

of fish and wildlife resources. The focus of management is on supporting the unique habitats and 

species found at Rose Atoll (e.g., Pisonia forest, lagoon habitat, perimeter reef, ava, seabirds, faisua, 

turtles, corals, fishes, etc.). 

On-site EE activities will be expected to cause some wildlife disturbance. Disturbance to nesting and 

resting seabirds and other migratory birds can include flushing birds or even raising their alert levels, 

creating stress and requiring animals to expend energy that will otherwise be invested in essential 

life-history activities such as foraging, mating, nesting, brood-rearing, and predator avoidance. Such 

stress reactions (elevated heart rate, elevated levels of corticosterone, and behavioral responses) have 

been documented in several species of nesting seabirds at several ecotourism locations as a result of 

human activities in nesting colonies (Jungius and Mirsch 1979, Fowler 1995, Nimon et al. 1995, 

Kitaysky et al., 2003). Disturbance can cause nest desertion; reduce survival of individual birds, 

eggs, nestlings, or broods; and alter behavior of nonbreeding birds (Trulio 2005). Kitaysky et al. 

(2003) showed that limited duration disturbance, however, has only minor, short-term effects. 

Observation periods for any particular bird or group of birds will be kept to 15 minutes or less for 

this reason. Bright lights from the boat may cause birds returning to the island at night to collide with 

the vessel. 

Sea turtles coming ashore to dig nests and lay eggs are highly focused on their reproductive behavior. 

Turtles are easily disturbed during the early stages of the nesting process. Hatchlings may have 

difficulty emerging from the nest, however, if the overlying sand has been compacted by 

considerable human trampling. Artificial light from night activities on shore or offshore ship lights 

may disorient hatchlings as they make their way to the ocean from their nest. Disturbance to fish, 

marine invertebrates, and corals may result during snorkeling, swimming, or diving activities 

(Hawkins et al. 1999). 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

C-20 Appendix C. Compatibility Determinations

As educators and students walk on the islands, trampling of native plants, benthic marine biota, 

erosion, and introduction or spread of nonnative species, including microbes, invertebrates, plants, 

algae, and other pest species could occur. All of these impacts will adversely affect native wildlife, 

plants, and their habitats; and will be of special concern in Refuge areas struggling with reestablishment of native plant communities. The degree of actual effects upon reproduction, survival 

of individuals, and diversity and abundance of native species (community health) will depend on 

specific circumstances. 

Improper boat operation could result in localized impacts to the coral reef from anchoring, touching, 

or other avoidable physical disturbance to the benthos including coral and crustose coralline algae 

(CCA). Lights on vessels working or transiting near the island at night may cause collisions with the 

vessel by birds returing to or leaving the island. 

Inexperienced or inattentive snorkelers and divers can also cause localized damage by standing on 

the reef, flushing sediment onto living reef biota, and breaking coral and CCA with hands or fins. 

Spread of nonnative or pest plants, invertebrates, or pathogens is possible from ground disturbance or 

transportation of equipment and personnel. These effects will be avoided or minimized by requiring 

proper cleaning of investigator equipment and clothing as well as adhering to quarantine methods 

and possibly restoration or mitigation plans, where appropriate. 

Due to the very limited nature of this activity (once every 3 years), the small group size (<10 people), 

accompaniment by Refuge-authorized personnel, selection of terrestrial and marine viewing areas 

based on limiting wildlife and habitat disturbance; and instruction and training provided prior and 

during the trip (including biosecurity protocols), we do not expect any additional short-term, longterm, or cumulative and indirect or secondary impacts from this use. 

Public Review and Comment: 

Public availability of this CD was widely announced together with announcement of the availability 

of the Refuge’s Draft CCP/EA. The review and comment period was also the same as for the Draft 

CCP/EA. Appendix J of the CCP contains a summary of the comments and Service responses. 

Determination: (check one below) 

 Use is Not Compatible 

 X Use is Compatible with following Stipulations 

Stipulations Necessary to Ensure Compatibility: 

Permission to use the Refuge for EE will be officially authorized through issuance of an SUP. 

Generally, an SUP may only be issued on a year-to-year basis. The SUP will cover use by a specified 

individual or organization and could not be assigned or sub-permitted to others. These permits may 

stipulate more detailed access restrictions and regulations to protect wildlife or Refuge integrity from 

anticipated site-specific negative effects caused by the EE project. At the discretion of the Refuge 

Manager, Refuge-approved staff may be assigned to accompany EE participants. 

The Refuge staff will supply EE participants with information about the Refuge; its purposes and 

goals; natural and cultural resources of concern; rules and regulations; and any hazardous conditions. 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

Appendix C. Compatibility Determinations C-21

Participants are responsible for reviewing and understanding this information and ensuring that any 

people entering the Refuge also received, reviewed, understood, and complied with this information. 

General 

1. In addition to the stipulations listed here, the general SUP conditions and requirements, and the 

special SUP conditions, EE participants are required to comply with Refuge System-related and 

other applicable laws, regulations, and policies including “Prohibited Acts” listed in Title 50 of 

the Code of Federal Regulations (CFR) 27. 

2. Only activities specifically authorized in an SUP will be permitted. Other activities are 

prohibited, for example (but not limited to): 

a. Rose Atoll NWR is closed to general public use, so the SUP will include maps clearly 

depicting the areas educators and students are authorized to access and use, including the 

Refuge entry point(s). Permittees are prohibited from straying outside the areas depicted on 

the maps and may be accompanied by a Refuge-authorized agent during their stay. 

b. Educators and students are prohibited from constructing new or maintaining existing 

structures on the Refuge without specific, prior written approval of the Refuge Manager. 

c. Consistent with Service policy regarding management of non-hazardous solid waste on 

refuges (561 FW 5), permittees are prohibited from littering, dumping refuse, abandoning 

equipment or materials, or otherwise discarding any items on the Refuge. 

d. Unless it was an element included in their approved project proposal, educators and their 

students are prohibited from collecting and removing any archaeological or historic artifacts, 

abiotic or biological specimens or samples, or mementos from the Refuge. 

3. Only educators who had successfully participated in an EE Refuge program will be allowed to 

lead EE groups at the Refuge. For activities at the Refuge, EE group size (including students, 

educators, parents, and others participating in the activity) will be limited to no more than 10 

individuals in the group per visit. 

4. To minimize the introduction of pests, equipment as well as educator’s and student’s clothing and 

vehicles (e.g., boats) need to be thoroughly cleaned (free of marine fouling organisms, dirt and 

plant material) before being used on the Refuge. 

5. Educators, students, and related personnel will adhere to best management practices to minimize 

wildlife disturbance while at the Refuge as identified by the Refuge Manager through their SUP. 

6. No changes may be made to any of these stipulations without specific, prior written approval of 

the Refuge Manager. 

Monitoring, Adaptive Management, and Enforcement 

1. The Refuge Manager has the right to add to or otherwise modify the stipulations listed herein in 

order to ensure the continued compatibility of this use. 

2. Violation of any of these stipulations could result in temporary or permanent withdrawal of 

official permission to continue EE on the Refuge. The Refuge Manager may also suspend or 

revoke the SUP if unacceptable impacts were occurring to native wildlife, plants, or their 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

C-22 Appendix C. Compatibility Determinations

habitats, cultural resources, or other Refuge visitors. The SUP may be revoked by the Refuge 

Manager immediately for non-compliance with these stipulations. 

Justification: 

Service policy states that EE programs can “... promote understanding and appreciation of natural 

and cultural resources and their management on all lands and waters in the Refuge System” (605 FW 

6). Service policy strongly encourages refuge managers to provide quality, compatible EE programs. 

There may be some potential for wildlife disturbance at the on-site location. Effects will be mitigated 

through timing of visits, instruction of participants, Refuge-authorized attendant, and other measures 

as identified previously. Stipulations will ensure that any other effects of EE will be minor or not 

measurable. 

Mandatory 10- or 15-Year Re-evaluation Date: 

 2028 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 

 X Environmental Assessment and Finding of No Significant Impact 

 Environmental Impact Statement and Record of Decision 

This CD has been developed and issued concurrent with the Final CCP for Rose Atoll NWR. 

Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

C-24 Appendix C. Compatibility Determinations

References Used and Cited, and Glossary of Acronyms and Terms: 

Endangered Species Act of 1973, as amended (16 U.S.C. 1531-1544).

Environmental Education (605 FW 6). 

Fowler, G.S. 1995. Ecotourism, field studies and stress: behavioral and hormonal responses of 

Magellanic penguins to nest site disturbance. In: Abstracts to Pacific Seabird Group Annual Meeting, 

1995. 

Hawkins, J.P., C.M. Roberts, T.V.T. Hof, K.D. Meyer, J. Tratalos, and C. Aldam. 1999. Effects of 

recreational scuba diving on Caribbean coral and fish communities. Conservation Biology 13(4):888-

897. 

Jungius, H. and U. Mirsch. 1979. Changes in heartbeats in nesting birds at Galapagos by human 

disturbance. Journal of Field Ornithology 120:299-310. 

Kitaysky, A., M. Benowitz-Fredericks, Z. Kitaiskaia, M. Shultz, and B. Zaun. 2003. Effects of tourist 

disturbance on stress physiology of wedge-tailed shearwaters (Puffinus pacificus) chicks at Kilauea 

Point National Wildlife Refuge, Kauai, Hawaii. Unpublished report. Kilauea Point National Wildlife 

Refuge. Kauai, HI. 

National Wildlife Refuge System Administration Act of 1966, as amended (16 U.S.C. 668dd-668ee). 

Nimon, A.J., R.C. Schroter, and B. Stonehouse. 1995. Heart rate of disturbed penguins. Nature 

374:415. 

Prohibited Acts (50 CFR 27). 

Refuge System-authorized agents: Include “... contractors, cooperating agencies, cooperating 

associations, refuge support groups, and volunteers” (603 FW 2).

Trulio, L. 2005. Science syntheses for Issue 9: understanding the effects of public access and 

recreation on wildlife and their habitats in the restoration project area. Available at: 

http://www.southbayrestoration.org/pdf_files/Issue%209%20Public%20Access%20&%20Wildlife.p

df. 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix D. Implementation D-1

Appendix D. Implementation

D.1 Overview

There are no guarantees that additional Federal funds will be made available to implement any or all 

of these projects. Therefore, implementation of the entire CCP will require funding which will be 

sought from a variety of sources. This plan will depend on additional appropriations, partnerships, 

and grants (both public and private). Activities and projects identified will be implemented as funds 

become available. Funding for Rose Atoll NWR for Fiscal Year 2012 was $291,550.

The CCP describes several projects to be implemented over the next 15 years. All of these projects 

are included in the Refuge Management Information System (Refuge Operational Needs System or 

Maintenance Management System), which are used to identify funding and resource needs.

Monitoring activities will be conducted on a percentage of all new and existing projects and activities 

to document wildlife populations and changes across time, habitat conditions, and responses to 

management practices. Actual monitoring and evaluation procedures will be detailed in SDMP (see 

below). In addition to the actual strategies outlined in the CCP, some activities will require more 

detailed plans. An Inventory and Monitoring Plan (by 2017) has been identified as an SDMP that will

be developed as part of implementation as well as a Wildlife Habitat Review (and if needed, Habitat 

Management Plan).

D.2 Costs to Implement CCP

The following sections detail both one-time and recurring costs for various projects. One-time costs 

(Table D-1) reflect the initial costs associated with a project, such as the purchase of equipment, 

contracting services, etc. Recurring costs (Tables D-2 and D-3) reflect the future operational and 

maintenance costs associated with the project. Table D-4 summarizes the total budgets needed to 

implement the CCP. The potential funding sources identify both base funding that is appropriated by 

Congress as part of the NWRS budget (e.g., 1261=operations, 1262=maintenance, 1263=visitor 

services, etc.) and grants/external funds received (e.g., Endangered Species [ES], Deferred 

Maintenance [DM], etc.). Note that for both tables D-1 and D-2, only costs the Refuge is directly 

responsible for have been identified. For partnering strategies identified, due to the unknown costs 

associated and timing, these costs have not been identified in the tables below. However some 

partnering costs have been identified in section D.4 (partnering opportunities).

Table D-1. One-Time Costs in Thousands

CCP Objective/Strategy Current 

($K)

Future 

($K)

Potential 

Fund Source

Obj. 1.1: Within 10 years characterize nutrient budgets and 

dynamics at Rose Atoll and evaluate them relative to data from 

other similar reef sites to identify possible stressors and the 

positive effects of healthy seabird colonies adjacent to living 

reefs

$30 1261

Obj. 1.1: Within 4 years, install a remote camera system to 

document boat traffic in the lagoon $100 1265
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

D-2 Appendix D. Implementation

CCP Objective/Strategy Current 

($K)

Future 

($K)

Potential 

Fund Source

Obj. 4.1: Within 10 years, investigate the ecological 

relationships between marine gastropods such as turban shells 

(Turbo spp.) and land hermit crabs (Coenobita perlatus and C. 

brevimanus). Evaluate factors affecting crab populations, 

including observed reduction in availability of shells to crabs 

at the Refuge and what management may improve mollusk 

shell availability to the Coenobita spp. which are important 

scavengers and herbivores on both islands

$100 1261

Obj. 6.1: Conduct study to determine if aquifer exists at Rose 

Atoll. If found, within 5 years, begin monitoring the lens to 

document extent and changes

TBD I&M

Obj. 7.1: Install minimal signage on Rose Island to inform 

people of Refuge boundary and regulations $1 $1 1263 or DFM

Obj. 7.1: Develop brochures, website, and utilize social media 

and other outreach tools specifically designed to communicate 

Refuge protection and safety issues and make these available 

to mariners

$30 1263

Obj. 7.1: Develop outreach messages using social media such 

as blogs or interpretive videos online to “bring the Refuge to 

the people”

$30 1263

Obj. 7.1: Enhance law enforcement through the production of 

interpretive brochures for distribution in American Samoa and 

to the yachting community and collaborate with the USCG and 

NOAA for enforcement

$150 1263 or 1265

Obj. 7.2: Create EE materials such as DVDs and posters for 

use with school groups $30 1263

Obj. 8.1: Restore the cement monument erected on Rose Island 

during the Governor’s 1920 visit $100 DFM

To support strategies, purchase of one vehicle for Refuge staff $30 1261

TOTAL: $1 $601

Table D-2. Recurring Operational Recurring Costs Annual in Thousands

CCP Objective/Strategy (these costs will run through the 

entire 15-year plan and are annual)

Current 

($K)

Future

($K)

Potential 

Fund 

Source

Obj. 1.1: Identify, prioritize, and implement restoration needs

such as debris removal in lagoon habitats affected by 

anthropogenic impacts such as iron contamination from 

shipwrecks

$10 $20 NRDA
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix D. Implementation D-3

CCP Objective/Strategy (these costs will run through the 

entire 15-year plan and are annual)

Current 

($K)

Future

($K)

Potential 

Fund 

Source

Obj. 1.1: Within 5 years, develop and implement monitoring 

protocols to track populations of focal lagoon species including

fish, corals, faisua, other invertebrates, and marine pests to 

determine abundance, density, and biomass of each at selected 

sites

$20

I&M 

grant or 

1261

Obj. 2.1: Continue monitoring abundance and distribution of the 

cyanobacteria community which became dominant on a section 

of the southwest arm of the atoll due to elevated iron levels 

following a 1993 shipwreck

$20 $60 NRDA

Obj. 2.1: Within 5 years, develop and implement monitoring 

protocols to track abundance and distribution of focal perimeter 

reef species including eels and urchins to determine abundance, 

density, and biomass of each at selected sites

$20

I&M 

grant or 

1261

Obj. 2.1: Monitor benthic succession of the reef which was 

damaged due to the 1993 shipwreck $20 NRDA

Obj. 2.1: Within 2 years, establish systematic marine debris 

removal program $10 NRDA

Obj. 3.1: Within 5 years, develop and implement monitoring 

protocol to track abundance and biomass of fish, including

predatory and prey fish species, around the opening of the ava to 

detect any changes in structure or function of this important 

geological feature for large predators in the Refuge

$10

I&M 

grant or 

1261

Obj. 3.1: Work toward the inclusion of better warnings about 

the hazard to mariners of waters in and near the ava to prevent 

vessel groundings, and improve public communications about 

the Refuge being closed

$10 1263

Obj. 4.1: Within 2 years, use GPS to map the perimeter of the 

islands at high and low tide on each visit to the Refuge and 

obtain any available satellite imagery for incorporation into GIS 

in order to document changes in island size and location

$5 PICCC 

grant

Obj. 4.1: Within 15 years, restore and protect native coastal 

plants using best available information about original 

indigenous ecosystem. Restore native tamole (Portulaca lutea) 

population that was extirpated on Rose Atoll by introduced rats 

(Rattus exulans) but survived on an offshore coral block. 

Monitor survivorship, growth, and maturation of planted tamole

$5 $5 1261

Obj. 4.1 & 5.1: Within 2 years, prepare and implement a 

monitoring plan and rapid response program for terrestrial 

nonnative pest species and respond immediately if detected

$35 ISST
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

D-4 Appendix D. Implementation

CCP Objective/Strategy (these costs will run through the 

entire 15-year plan and are annual)

Current 

($K)

Future

($K)

Potential 

Fund 

Source

Obj. 5.1: Within 10 years, eradicate the scale insect (Pulvenaria 

urbicola) and any other nonnative insects, specifically focusing 

on eradicating introduced ant species that facilitate scale growth 

and spread

$40 ISST

Obj. 5.1: Continue monitoring presence or absence of breeding 

bird populations (annual or less often depending on visit 

schedule to the Refuge) as one indicator of the success of 

habitat restoration measures

$5 1261

Obj. 5.1: Within 3 years, develop and implement a monitoring 

protocol to track seabird abundance, nesting rates, and feeding 

territories. Include remote camera observations to improve 

future monitoring efforts

$10

I&M 

grant or 

1261

Obj. 5.1: Within 4 years, review available vegetation data and 

develop and implement a monitoring protocol to track changes 

in numbers, cover, and basal area of different species

$3 1261

Obj. 5.1: Within 2 years, review existing vegetation community 

distribution data and develop GIS database of terrestrial and 

marine habitats and update them regularly

$4

I&M 

grant or 

1261

Obj. 5.1: Maintain cover of niu (Cocos nucifera) at or below 5% 

using mechanical removal or direct application of herbicides as 

appropriate

$1 $1 ISST or 

1262

Obj. 5.1: Within 5 years, implement restoration design and 

begin outplanting vegetation if required TBD 1261

Obj. 6.1: Within 5 years, begin to monitor climate change 

variables including sea level, temperature (air/water/substrate), 

water quality (pH, conductivity, dissolved oxygen, nitrogen, 

photosynthetically available light (PAR), phosphorus, iron) and 

the frequency and duration of extreme storm events and 

biological responses (phenological, developmental, 

physiological)

$15

PICCC 

grant or 

I&M

Obj. 6.1: Within 5 years, monitor the growth and survival rate of 

coral colonies at different depths $10 I&M

Vessel acquisition and maintenance for management, law 

enforcement, and monitoring:

full ownership; 

partial ownership; or 

contract of a vessel for management.

$20

- $550

- $275

- $60

1262
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix D. Implementation D-5

CCP Objective/Strategy (these costs will run through the 

entire 15-year plan and are annual)

Current 

($K)

Future

($K)

Potential 

Fund 

Source

TOTAL: $61 $294 +

$12 (5 year 

interval veg. 

mapping) +

• $550

• $275

• $60

(vessel 

options)

Costs identified below in Table D-3 include salary, COLA, and benefits (applicable only to Federal 

employees). The Refuge/Monument Manager is supported by staff in Honolulu (notably the 

biologist) that are part of the larger Pacific Reefs National Wildlife Refuge Complex (Complex). 

Therefore (*) positions are these Complex positions and staffing costs identified for these positions is 

equally proportioned among the other refuges in the Complex.

Table D-3. Staffing Costs (annual in thousands)

Staff Current

($K)

Future

($K)

Potential Funding 

Source

Current Staff

Refuge/Monument Manager (GS-12) – Permanent $117,392 $117,392 1261

Staff at Honolulu Complex Headquarters also supporting Rose Atoll NWR

Superintendent/Project Leader (GS-14)* –

Permanent $16,309 $16,309 1261

Wildlife Biologist (GS-12)* – Permanent $12,594 $12,594 1261

Administrative Officer (GS-9)* – Permanent $8,859 $8,859 1261

Planned Additional Staff

Wildlife Biologist (GS-11) $84,411 1261

Biological Technician (GS-7) $57,404 1261

Admin officer (GS-5/7) $57,404 1261

Park Ranger (GS-5/7) – Half time $28,702 1261

TOTAL: $155,154 $383,075

In 2008, the Refuge System undertook a comprehensive review of staffing needs on all refuges based 

on a set of 15 standard criteria (e.g., acreage, annual public visitation, number of invasive species 

populations, etc.). The staffing needs identified under this review (National Staffing Model) for Rose 

NWR/MNM was 4.5.
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

D-6 Appendix D. Implementation

The following table summarizes data from Tables D-1 through D-3 and displays the overall funding 

needed for the Refuge to implement the CCP.

Table D-4. Budget Summary (annual in thousands/millions)

Budget Category

Current Management Future Management

One-time 

Cost

Annual Recurring 

Cost

One-time Cost Annual Recurring 

Cost

Management 

Actions

$1,000 $61,000 x 15 years 

= $915,000

$601,000 $294,000 x 15 

years +

$12,000 (5-year 

interval veg. 

mapping) +

$550,000

$275,000

$60,000 

(vessel option 

range)

= 

$4,972,000

$4,697,000

$4,482,000

Staffing $155,154 x 15 years = $2,327,310 $383,075 x 15 years = $5,746,125

TOTAL: $3,243,310 $11,319,125

$11,044,125

$10,829,125

D.3 Timeline for CCP Implementation

The following table depicts the timeline for implementing the strategies outlined in Chapter 2. As 

stated previously, the timeline is funding dependent but does reflect Refuge priorities. 

Table D-5. Timeline for Implementation of Management Direction

CCP Objective/strategy Implementation Year

Obj. 4.1: Within 6 months, revise existing biosecurity measures to 

comprehensively address prevention of introducing nonnative pest species to 

the atoll

6 months (2014)

Obj. 1.1: Identify, prioritize, and implement restoration needs such as debris 

removal in lagoon habitats affected by anthropogenic impacts such as iron 

contamination from shipwrecks

Year 1 (2014) to 

identify/prioritize 

(implementation TBD 

based on findings)

Obj. 6.1: Finalize Memorandum of Understanding (MOU) with DMWR to 

coordinate data collection and management activities at the Refuge Year 1 (2014)

Obj. 8.1: Work with the American Samoa Historical Preservation Office to 

conduct an archaeological survey at Rose Atoll Year 1 (2014)
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix D. Implementation D-7

CCP Objective/strategy Implementation Year

Obj. 8.1: Work with partners to create information materials such as videos, 

reports, and pamphlets regarding cultural uses and the oral history of Rose 

Atoll

Year 1 (2014)

Obj. 2.1: Within 2 years, establish systematic marine debris removal program Year 2 (2015)

Obj. 4.1 and 6.1: Within 2 years, use GPS to map the perimeter of the islands 

at high and low tide on each visit to the Refuge and obtain any available 

satellite imagery for incorporation into GIS in order to document changes in 

island size and location

Year 2 (2015)

Obj. 4.1 and 6.1: Within 2 years, working with NOAA/NMFS, DMWR, and 

other partners, develop and implement monitoring protocol to track turtle 

abundance and movements using field counts, tagging, a remote camera 

system, and satellite telemetry

Year 2 (2015)

Obj. 4.1, 5.1, and 6.1: Within 2 years, prepare and implement a monitoring 

plan and rapid response program for terrestrial nonnative species and respond 

immediately if detected

Year 2 (2015)

Obj. 5.1 and 6.1: Within 2 years, review existing vegetation community 

distribution data and develop GIS database of terrestrial and marine habitats 

and update them regularly

Year 2 (2015)

Obj. 8.1: Research the history of Samoan names for Rose Atoll and consider 

changing Refuge name accordingly Year 2 (2015)

Obj. 1.1 and 6.1: Work with partners to conduct REA to document habitat 

associations and species distribution, density, and diversity in marine habitats Year 3 (2016)

Obj. 3.1: Work toward the inclusion of better warnings about the hazard to 

mariners of waters in and near the ava to prevent vessel groundings, and 

improve public communications about the Refuge being closed

Year 3 (2016)

Obj. 5.1: Within 3 years and working with experts, prepare a restoration design 

that identifies which desired species will require active propagation and 

outplanting and which will recruit naturally now that rat herbivory has been 

eliminated. Part of this strategy will be to work with universities and other 

partners to investigate composition and structure of terrestrial communities on 

Rose Island prior to the introduction of rats to inform ecological restoration 

activities (see Objective 6.2)

Year 3 (2016)

Obj. 5.1 and 6.1: Within 3 years, develop and implement a monitoring protocol 

to track seabird abundance, nesting rates, and feeding territories. Include 

remote camera observations to improve future monitoring efforts

Year 3 (2016)

Obj. 7.1: Explore opportunities and community interest for supporting the 

development of a Refuge “Friends” group to help with interpretation, outreach, 

and other Refuge needs

Year 3 (2016)

Obj. 7.1: Install minimal signage on Rose Island to inform on Refuge boundary 

and regulations Year 3 (2016)
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

D-8 Appendix D. Implementation

CCP Objective/strategy Implementation Year

Obj. 7.1: Develop brochures, website, social media, and other outreach tools 

specifically designed to communicate Refuge protection and safety issues and 

make these available to mariners

Year 3 (2016)

Obj. 7.2: Create EE materials such as DVDs and posters for use with school 

groups Year 3 (2016)

Obj. 7.2: Develop a brief, picture-oriented Powerpoint presentation describing 

the ecology of the Refuge and present this to three American Samoa schools 

each year

Year 3 (2016)

Obj. 7.2: Develop a student intern program with the Refuge office to introduce 

students to protected areas and wildlife management Year 3 (2016)

Obj. 1.1: Within 4 years, install a remote camera system to document boat 

traffic in the lagoon Year 4 (2017)

Obj. 5.1 and 6.1: Within 4 years, review available vegetation data and develop 

and implement a monitoring protocol to track changes in numbers, cover, and 

basal area of different species

Year 4 (2017)

Obj. 7.1: Work with partners to develop interpretive displays and printed 

materials to provide outreach messages at visitor centers as well as mobile 

displays for traveling exhibits

Year 4 (2017)

Obj. 7.2: Explore appropriate on-site EE opportunities (<once every 3 years) to 

allow a small group of teachers and students (<10 people) to visit the Refuge 

for specific EE purposes developed with the Refuge’s EE program

Year 4 (2017)

Obj. 1.1 and 6.1: Within 5 years, develop and implement monitoring protocols 

to track populations of focal lagoon species including fish, corals, faisua, other 

invertebrates, and marine pests to determine abundance, density, and biomass 

of each at selected sites

Year 5 (2018)

Obj. 2.1 and 6.1: Within 5 years, work with partners to develop and implement 

reef monitoring program, including rate of growth, elevation change, chemical 

composition and other variables related to reef growth and the atoll’s ability to 

maintain itself in an anticipated environment of climate change and ocean 

acidification

Year 5 (2018)

Obj. 2.1 and 6.1: Within 5 years, develop and implement monitoring protocols 

to track abundance and distribution of focal perimeter reef species including 

eels and urchins to determine abundance, density, and biomass of each at 

selected sites

Year 5 (2018)

Obj. 3.1 and 6.1: Within 5 years, work with partners to monitor water flow rate 

and direction in the ava using archival pressure and flow rate instruments that 

can be downloaded at every visit in order to document any changes in flow 

through the ava

Year 5 (2018)

Obj. 3.1 and 6.1: Within 5 years, develop and implement monitoring protocol 

to track abundance and biomass of fish, including predatory and prey fish 

species, around the opening of the ava to detect any changes in structure or 

function of this important geological feature for large predators in the Refuge

Year 5 (2018)
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix D. Implementation D-9

CCP Objective/strategy Implementation Year

Obj. 4.1 Within 5 years, working with NOAA/NMFS and other partners, 

develop a cooperative management plan with Fiji to protect shared stocks of 

threatened green turtles that migrate between Rose Atoll (to nest) and Fiji (to 

feed). Meet with appropriate Fiji managers as needed

Year 5 (2018)

Obj. 4.1 and 6.2: Within 5 years, work with universities and other partners to 

evaluate the geomorphology, hydrology, and sediment budget of Rose Atoll to 

understand the processes that have maintained the islands as dynamic units

Year 5 (2018)

Obj. 5.1: Within 5 years, implement restoration design and begin outplanting 

vegetation if required Year 5 (2018)

Obj. 6.1: Within 5 years, begin to monitor climate change variables including 

sea level, temperature (air/water/substrate), water quality (pH, conductivity, 

dissolved oxygen, nitrogen, photosynthetically available light (PAR), 

phosphorus, iron) and the frequency and duration of extreme storm events and 

biological responses (phenological, developmental, physiological)

Year 5 (2018)

Obj. 6.1: Within 5 years, monitor the growth and survival rate of coral colonies 

at different depths Year 5 (2018)

Obj. 7.1: Develop outreach messages using social media such as blogs or 

interpretive videos on line to “bring the Refuge to the people” Year 5 (2018)

Obj. 7.1: Enhance law enforcement through the production of interpretive 

brochures for distribution in American Samoa and to the yachting community 

and collaborate with the USCG and NOAA for enforcement

Year 5 (2018)

Obj. 7.1: Develop a Refuge volunteer program to provide local and national 

stewardship opportunities and assist in Refuge management activities Year 5 (2018)

Obj. 1.1 and 6.2: Within 10 years characterize nutrient budgets and dynamics 

at Rose Atoll and evaluate them relative to data from other similar reef sites to 

identify possible stressors and the positive effects of healthy seabird colonies 

adjacent to living reefs

Year 10 (2023)

Obj. 4.1 and 6.2: Within 10 years, investigate the ecological relationships 

between marine gastropods such as turban shells (Turbo spp.) and land hermit 

crabs (Coenobita perlatus and C. brevimanus). Evaluate factors affecting crab 

populations, including observed reduction in availability of shells to crabs at 

the Refuge and what management may improve mollusk shell availability to 

the Coenobita spp. which are important scavengers and herbivores on both 

islands

Year 10 (2023)

Obj. 5.1: Within 10 years, eradicate the scale insect (Pulvenaria urbicola) and 

any other nonnative insects, specifically focusing on eradicating introduced ant 

species that facilitate scale growth and spread

Year 10 (2023)

Obj. 8.1: Restore the cement monument erected on Rose Island during the 

Governor’s 1920 visit Year 10 (2023)

Obj. 6.2: Work with universities and other partners to investigate food habits of 

seabirds breeding at Rose Atoll using stable isotopes and stomach samples Over lifespan of plan
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

D-10 Appendix D. Implementation

CCP Objective/strategy Implementation Year

Obj. 6.2: Work with universities and other partners to correlate reproductive 

performance indicators and breeding chronology variation with oceanographic 

conditions and location of migratory fish schools relative to the atoll

Over lifespan of plan

Obj. 1.1 and 6.1: Work with NOAA’s CRED and other partners to collect 

oceanographic and water quality data in order to track changes that could affect 

the reef or wildlife

Ongoing

Obj. 1.1, 3.1, and 6.1: Work with partners to collect bathymetry data every 10 

years in order to document changes in the lagoon, reef, or ava that could affect 

hydrography or habitat characteristics

Ongoing

Obj. 2.1: Continue monitoring abundance and distribution of the cyanobacterial 

community which became dominant on a section of the southwest arm of the 

atoll due to elevated iron levels following a 1993 shipwreck

Ongoing

Obj. 2.1 and 6.1: Monitor benthic succession of the reef which was damaged 

due to the 1993 shipwreck Ongoing

Obj. 4.1 and 6.1: Within 15 years, restore and protect native coastal plants 

using best available information about original indigenous ecosystem. Restore 

native tamole (Portulaca lutea) population that was extirpated on Rose Atoll 

by introduced rats (Rattus exulans) but survived on an offshore coral block. 

Monitor survivorship, growth, and maturation of planted tamole

Ongoing

Obj. 5.1: Continue monitoring presence or absence of breeding bird 

populations (annual or less often depending on visit schedule to the Refuge) as 

one indicator of the success of habitat restoration measures

Ongoing

Obj. 5.1: Maintain cover of niu (Cocos nucifera) at or below 5% using 

mechanical removal or direct application of herbicides as appropriate Ongoing

Obj. 6.1: Work with partners to monitor status and trends of focal communities 

(hard corals, algae), including the incidence and severity of coral and algal 

disease and bleaching

Ongoing

Obj. 6.1: Work with partners to deploy an Ecological Acoustic Recorder 

(EAR) in the ava to collect biological data that may improve monitoring of 

behavior and abundance of marine organisms

Ongoing

Obj. 7.1: Maintain Refuge website and update at least annually with current 

information such as species lists, interactive tools, management updates, news 

releases, science reports, etc.

Ongoing

Obj. 7.1: Participate in community meetings and local events to educate people 

about the Refuge, especially within the Manu’a Islands Ongoing

Obj. 7.1: Work with partners to deploy an EAR in the ava to collect data on 

boat entry into the lagoon Ongoing

Obj. 7.2: Work with partners to develop EE curriculum and classroom 

materials that introduce students to American Samoa wildlife, protected areas, 

and conservation of natural resources, especially in relation to effects from 

man-made climate change

Ongoing
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix D. Implementation D-11

CCP Objective/strategy Implementation Year

Obj. 7.2: Partner with schools and universities to conduct surveys and/or 

relevant research Ongoing

Obj. 8.1: Consult with the OSA and local villagers to understand and 

perpetuate Refuge-appropriate traditional cultural practices related to Rose 

Atoll

Ongoing

D.4 Partnering Opportunities

Partnerships are an important component of the implementation of this CCP. The Refuge has never 

been fully funded to accomplish adequate Refuge management. Towards this end, we rely on 

partnering opportunities to assist with this shortfall, both in terms of funding and personnel.

Partnering opportunities are reflected in the goals, objectives, and strategies identified in Chapter 2.

Coordinated partnership efforts focus on species and habitat restoration and protection; surveys, 

inventories, and research; and cultural resources management. Refuge staff will work to strengthen 

existing partnerships and will actively look for new partnerships to assist in achieving the goals, 

objectives, and strategies in this CCP.

The following list of partners and recently funded projects provides some information on how the 

Refuge has benefitted from partnerships for Refuge management. This information illuminates how 

partnering is critical for the Refuge to accomplish species and habitat restoration and protection.

• Refuge Inventory and Monitoring Program has funded a survey of arthropods and 

distribution of invasive ants on Rose Atoll and development of methods ($38,437);

• The ASCC, USGS, and AmeriCorps provided entomologists to conduct arthropod surveys;

• The NOAA CRED has conducted coral reef assessment and monitoring surveys in the 

Refuge and adjoining fore reef biannually since 2002, providing more than a dozen 

specialists each survey period in oceanography, fishes, corals, other invertebrates, algae, and 

data management. NOAA vessels have also provided Refuge access for Service terrestrial 

biologists and American Samoa government representatives, including the Governor;

• The DMWR has provided biologists for monitoring and management actions, as well as 

assisting with transportation to the Refuge;

• The NMFS provided funds for a trip to Rose Atoll for Manu’a chiefs, teachers, and students;

• The ONMS and ASDOC provided staff on the trip funded by NMFS;

• The NPS and ASHPO provided archeologists to conduct the first in-depth archeology survey 

of Rose Island;

• The NPS provided experienced scuba divers to conduct coral surveys; and

• The NPS provides office space and support for the Refuge/Monument office.
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

D-12 Appendix D. Implementation
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix E. Wilderness Review E-1

Appendix E. Wilderness Review for Rose Atoll NWR

E.1 Policy and Direction for Wilderness Reviews

U.S. Fish and Wildlife Service policy (Part 602 FW 3.4 C.(1) (c)) requires that wilderness reviews be 

completed as part of the CCP process. This review includes the re-evaluation of refuge lands existing 

during the initial 10-year review period of The Wilderness Act of 1964, as amended (16 U.S.C. 

1131-1136), as well as new lands and waters added to the Refuge System since 1974. A preliminary 

inventory of the wilderness resources is to be conducted during pre-acquisition planning for new or 

expanded refuges (341 FW 2.4 B - Land Acquisition Planning). Refuge System policy on Wilderness 

Stewardship (610 FW 1–5) includes guidance for conducting wilderness reviews (610 FW 4 -

Wilderness Review and Evaluation). 

A wilderness review is the process of determining whether the Service should recommend Refuge 

System lands and waters to Congress through the Department of the Interior and President for 

wilderness designation. The wilderness review process consists of three phases: wilderness 

inventory, wilderness study, and wilderness recommendation.

E.1.1 Wilderness Inventory

The inventory is a broad look at a refuge to identify lands and waters that meet the minimum criteria 

for wilderness: size, naturalness, and outstanding opportunities for solitude or primitive and 

unconfined type of recreation. All areas meeting the criteria are preliminarily classified as 

Wilderness Study Areas (WSA). If WSA are identified, the review proceeds to the study phase. 

E.1.2 Wilderness Study

During the study phase, WSAs are further analyzed: 

1) For all values ecological, recreational, cultural, economic, symbolic;

2) For all resources, including wildlife, vegetation, water, minerals, soils;

3) For existing and proposed public uses;

4) For existing and proposed refuge management activities within the area; and 

5) To assess a refuge’s ability to manage and maintain the wilderness character in 

perpetuity, given the current and proposed management activities. Factors for evaluation 

may include, but are not limited to, staffing and funding capabilities, increasing 

development and urbanization, public uses, and safety.

We evaluate at least an “All Wilderness Alternative” and a “No Wilderness Alternative” for each 

WSA to compare the benefits and impacts of managing the area as wilderness as opposed to 

managing the area under an alternate set of goals, objectives, and strategies that do not involve 

wilderness designation. We may also develop “Partial Wilderness Alternatives” that evaluate the 

benefits and impacts of managing portions of a WSA as wilderness.

In the alternatives, we evaluate:

1) The benefits and impacts to wilderness values and other resources;

2) How each alternative would achieve the purposes of the Wilderness Act and the NWPS;
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

E-2 Appendix E. Wilderness Review

3) How each alternative would affect achievement of refuge purpose(s) and the Refuge 

System mission;

4) How each alternative would affect maintaining and, where appropriate, restoring BIDEH 

at various landscape scales;

5) Other legal and policy mandates; and 

6) Whether a WSA can be effectively managed as wilderness by considering the effects of 

existing private rights, land status and Service jurisdiction, refuge management activities 

and refuge uses and the need for or possibility of eliminating Section 4(c) prohibited 

uses.

E.1.3 Wilderness Recommendation 

If the wilderness study demonstrates that a WSA meets the requirements for inclusion in the NWPS, 

a wilderness study report should be written that presents the results of the wilderness review, 

accompanied by a Legislative Environmental Impact Statement (LEIS). The wilderness study report 

and LEIS that support wilderness designation are then transmitted through the Secretary of the 

Interior to the President of United States, and ultimately to the Congress for action. Refuge lands 

recommended for wilderness consideration by the wilderness study report would retain their WSA 

status and be managed as “... wilderness according to the management direction in the final CCP 

until Congress makes a decision on the area or we amend the CCP to modify or remove the 

wilderness recommendation” (610 FW 4.22B). When a WSA is revised or eliminated, or when there 

is a revision in “wilderness stewardship direction, we include appropriate interagency and tribal 

coordination, public involvement, and documentation of compliance with NEPA” (610 FW 3.13).

The following constitutes the wilderness inventory phase of the wilderness review for the Rose Atoll 

NWR.

E.2 Wilderness Inventory

E.2.1 Criteria for Evaluating Lands for Possible Inclusion in the National 

Wilderness Preservation System

The Wilderness Act of 1964, as amended (16 U.S.C. 1131-1136), provides the following description 

of wilderness:

“A wilderness, in contrast with those areas where man and his own works dominate the 

landscape, is hereby recognized as an area where the earth and its community of life are 

untrammeled by man, where man himself is a visitor who does not remain. An area of 

wilderness is further defined to mean in this Act as an area of undeveloped Federal land 

retaining its primeval character and influence, without permanent improvements or human 

habitation, which is protected and managed so as to preserve its natural conditions...”

The following criteria for identifying areas as wilderness are outlined in Section 2(c) of the Act and 

are further expanded upon in NWRS policy (610 FW 4). The first three criteria are evaluated during 

the wilderness inventory phase; the fourth criterion is evaluated during the wilderness study phase:

1) Generally appears to have been affected primarily by the forces of nature, with the 

imprint of man’s work substantially unnoticeable; 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix E. Wilderness Review E-3

2) Has outstanding opportunities for solitude or a primitive and unconfined type of 

recreation;

3) Has at least 5,000 acres of land or is of a sufficient size as to make practicable its 

preservation and use in an unimpaired condition; and

4) May also contain ecological, geological, or other features of scientific, educational, 

scenic, or historic value. 

Criterion 3 is further defined in Section 3(c) of the Act as: 1) a roadless area of 5,000 contiguous 

acres or more, or 2) a roadless island. Roadless is defined as the absence of improved roads suitable 

and maintained for public travel by means of four-wheeled, motorized vehicles that are intended for 

highway use.

E.3 Process of Analysis

The following evaluation process was used in identifying the suitability of refuge units for wilderness 

designation:

 Determination of refuge unit sizes;

 Assessment of the units’ capacity to provide opportunities for solitude or primitive and 

unconfined recreation; and

 Assessment of “naturalness” of refuge units.

More detail on the actual factors considered and used for each assessment step follows.

Unit Size: Roadless areas meet the size criteria if any one of the following standards apply:

 An area with over 5,000 contiguous acres solely in Service ownership.

 A roadless island of any size. A roadless island is defined as an area surrounded by 

permanent waters or an area 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.

Inventory Unit A consists of the entire Rose Atoll NWR (Figure E-1) at 1,613 acres. As a low-lying 

atoll with two roadless islands, Rose Atoll NWR meets the size criteria for a wilderness study area.

Outstanding Solitude or Primitive or Unconfined Recreation.

A designated wilderness area must provide outstanding opportunities for solitude, or a primitive and 

unconfined type of recreation. Possession of only one of these outstanding opportunities is sufficient 

for an area to qualify as wilderness, and it is not necessary for one of these outstanding opportunities 

to be available on every acre. Furthermore, an area does not have to be open to public use and access 

to qualify under these criteria.
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

E-4 Appendix E. Wilderness Review

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 non-motorized, dispersed outdoor recreation 

activities that are compatible and do not require developed facilities or mechanical transport.

Primitive recreation activities may provide opportunities to experience challenge and risk, selfreliance, and adventure.

Solitude is an overwhelming force that visitors experience on Rose Atoll. The atoll is over 2,700 

miles to Sydney, Australia; 4,700 to Los Angeles, California; and 6,000 miles to Peru. The closest 

inhabited area is Ta’u Island at almost 80 miles away. Expanses of open ocean with no other 

landform are visible from every angle. Since its establishment as a refuge, Rose Atoll has been 

closed to general public access in order to conserve the unique and valuable fish and wildlife 

resources. Research, survey, and management activities involving human presence are infrequent and 

temporary and thus would not detract from opportunities for solitude or primitive and unconfined 

recreation. With no freshwater or facilities, a challenging channel crossing, extreme isolation, and 

sharks present in the lagoon, opportunities to experience challenge and risk, self-reliance, and 

adventure are present. 

The Rose Atoll NWR inventory unit thus meets the criteria for solitude as well as primitive and 

unconfined recreation.

Naturalness and Wildness: the area generally appears to have been affected primarily by the 

forces of nature, with the imprint of man’s work substantially unnoticeable.

This criterion must be evaluated in the context of current natural conditions and societal values and 

expectations without compromising the original intent of the Wilderness Act. It is well recognized 

that there are few areas remaining on the planet that could be truly classified as primeval or pristine, 

with even fewer, if any, existing in the conterminous U.S. Likewise, few areas exist that do not 

exhibit some impact from anthropogenic influences, be it noise, light, or air pollution; water quality 

or hydrological manipulations; past and current land management practices; roads or trails, 

suppression of wildfires; invasions by pest species of plants and animals; or public uses. While 

allowing for the near-complete pervasiveness of modern society on the landscape, the spirit of the 

Wilderness Act is to protect lands that still retain the wilderness qualities of: 1) natural, 2) 

untrammeled, 3) undeveloped. These three qualities are cornerstones of wilderness character. For 

areas proposed or designated as wilderness, wilderness character must be monitored to determine 

baseline conditions and thereafter be periodically monitored to assess the condition of these 

wilderness qualities. Proposed and designated wilderness areas by law and policy are required to 

maintain wilderness character through management and/or restoration in perpetuity.

Defining the first two qualities (natural and untrammeled) requires a knowledge and understanding of 

the ecological systems which are being evaluated as potential wilderness. Ecological systems are 

comprised of three primary attributes: composition, structure, function. Composition is the 

components that make up an ecosystem, such as the habitat types, native species of plants and 

animals, and abiotic (physical and chemical) features. These contribute to the diversity of the area.

Structure is the spatial arrangement of the components that contribute to the complexity of the area.

Composition and structure are evaluated to determine the naturalness of the area. Function is the 

processes that result from the interaction of the various components both temporally and spatially, 

and the disturbance processes that shape the landscape. These processes include but are not limited to 

predator-prey relationships, insect and disease outbreaks, nutrient and water cycles, decomposition, 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix E. Wilderness Review E-5

fire, windstorms, flooding, and both general and cyclic weather patterns. Ecological functions are 

evaluated to determine the wildness or untrammeled quality of the area. 

The third quality assessment is whether an area is undeveloped. Undeveloped refers to the absence of 

permanent structures such as roads, buildings, dams, fences, and other human alterations to the 

landscape. Exceptions can be made for historic structures or structures required for safety or health 

considerations, providing they are made of natural materials and relatively unobtrusive on the 

landscape.

General guidelines used for evaluating areas for wilderness potential during this wilderness inventory 

process include:

1) The area should provide a variety of habitat types and associated abiotic features, as well 

as a nearly complete complement of native plants and wildlife indicative of those habitat 

types. Pest species should comprise a negligible portion of the landscape.

2) The area should be spatially complex (vertically and/or horizontally) and exhibit all 

levels of vegetation structure typical of the habitat type, have an interspersion of these 

habitats, and provide avenues for plant and wildlife dispersal.

3) The area should retain the basic natural functions that define and shape the associated 

habitats including but not limited to flooding regimes, fire cycles, unaltered hydrology 

and flowage regimes, and basic predator-prey relationships including herbivory patterns.

4) Due to their size, islands may not meet the habitat guidelines in 1 and 2 above. Islands 

should, however, exhibit the natural cover type with which they evolved and continue to 

be shaped and modified by natural processes. Islands should be further analyzed during 

the study portion of the review, if they provide habitat for a significant portion of a 

population, or key lifecycle requirements for any resources of concern, or listed species. 

5) Potential wilderness areas should be relatively free of permanent structures or human 

alterations. Areas may be elevated to the study phase if existing structures or alterations 

can be removed or remediated within a reasonable timeframe, and prior to wilderness 

recommendation to the Secretary of the Interior. 

Rose Atoll’s remote location and difficult access have allowed nature to remain the primary sculpting 

force of the atoll’s resources, leaving ecological composition, structure, and function intact. Crustose 

coralline algae continue to build up the reef crest on the perimeter reef. The littoral forest and beach 

strand host colonies of seabirds and migratory shorebirds and nesting green turtles. Underwater, 

patch coral reefs and pinnacles support a dense community of fish, foraging green and hawksbill 

turtles, and faisua. There is a complete complement of native plants and wildlife indicative of habitat 

types with pest species comprising a negligible portion of the landscape.

The 1993 grounding of the longliner Jin Shiang Fa and resultant oil spill and wreckage have not 

affected the Refuge’s overall naturalness, despite damages on the southwestern side of the perimeter 

reef. All visible debris from the grounding has been removed as of 2007 and the atoll continues to 

recover. Other forms of marine debris have been rarely observed and do not constitute a significant 

visual presence in the atoll. There is only one monument, which cannot be seen from the lagoon.

Physical evidence of management and research activities are limited to a few monitoring plots on 

Rose Island and in reef areas, composed of PVC and steel, as well as infrequent, temporary field 

camps. These features are substantially unnoticeable in the Refuge as a whole.
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

E-6 Appendix E. Wilderness Review

The Rose Atoll NWR meets the naturalness criteria for a wilderness study area.

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.”

One of the smallest atolls in the world, Rose supports the largest populations of faisua, nesting sea 

turtles, nesting seabirds, and rare species of fish in American Samoa. The diversity of coral species in 

the atoll is significant given its small size. Rose Island is the most important seabird colony in the 

region due to the rat-free habitat. These resources, along with the atoll’s small size, well-defined 

boundaries, and limited anthropogenic influence make it of significant value for studying the 

processes of atoll systems. Healthy crustose coralline algae, the primary reef-building species, give 

Rose a striking pink hue. More water pours into the lagoon over the reef crest than exits the ava and 

causes the reef crest to grow higher, which makes it one of the few atolls with an elevated lagoon and 

enriches its scenic quality. The Refuge has ecological, geological, or other features of scientific and 

educational values which enhance wilderness characteristics.

E.4 Inventory Summary and Conclusion

Based on the analysis conducted above, Unit A meets the wilderness inventory criteria; therefore a 

wilderness study, in coordination with the American Samoan government and others, is 

recommended.

Wilderness Inventory Analysis Inventory Unit A: Rose 

Atoll NWR (1,613 ac)

(1) Has at least 5,000 acres of land or is of sufficient size to make 

practicable its preservation and use in an unconfined condition, or is a 

roadless island.

Yes

(2) Generally appears to have been affected primarily by the forces of 

nature, with the imprint of man’s work substantially unnoticeable. Yes

(3a) Has outstanding opportunities for solitude. Yes

(3b) Has outstanding opportunities for a primitive and unconfined type 

of recreation. Yes

(4) Contains ecological, geological, or other features of scientific, 

educational, scenic, or historical value.

Yes (ecological, geologic, 

scientific, educational value)

Parcel qualifies as a wilderness study area (meets criteria 1, 2 & 3a or 

3b). Yes
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix E. Wilderness Review E-7

Figure E-1. Wilderness Inventory Unit A, Rose Atoll NWR.
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

E-8 Appendix E. Wilderness Review

The back sides of maps are blank to improve readability.
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix F. Biological Resources of Concern F-1

Appendix F. Biological Resources of Concern

F.1. Introduction

Early in the planning process, the team cooperatively identified species, species groups, and

communities of concern for the Refuge. A comprehensive list of these resources was compiled based 

on review of numerous plans, many of which highlight priority species or habitats for conservation.

The Comprehensive Resources of Concern table was further culled in developing a more targeted 

assemblage of Priority Resources of Concern. Most of the biological emphasis of the CCP is focused 

on maintaining and restoring these priority resources. 

Definitions for the column headings in Table F-2 are as follows:

 Focal Species: Species selected as representatives or indicators for the overall condition of 

the conservation target. In situations where the conservation target may include a broad 

variety of habitat structures and plant associations, several different conservation focal 

species may be listed. In addition, species with specific “niche” ecological requirements may 

be listed as a focal species. Management will be focused on attaining conditions required by 

the focal species. Other species utilizing the conservation target will generally be expected to 

benefit as a result of management for the focal species.

 Habitat Type: The general habitat description utilized by the focal species.

 Habitat Structure: The specific and measurable habitat attributes considered necessary to 

support the focal species.

 Life-History Requirement: The general reason of use for the focal species.

 Other Benefiting Species: Other species that are expected to benefit from management for the

selected focal species. The list is not comprehensive; see Appendix A for a more complete 

list.

Table F-1. Biological Integrity, Diversity, and Environmental Health

Habitats Population/Habitat 

Attributes

Natural Processes 

Responsible for These 

Conditions

Limiting Factors

Lagoon Lagoon floor (to ~98 feet 

depth) and back reef 

composed of carbonate 

sand and rubble, with low 

coral and CCA cover (< 

1%). Hard-substrate 

pinnacles and patch reefs 

with moderate coral and 

CCA cover (>10%), 

supporting diverse fish 

assemblage and faisua

Potential conservation 

species: faisua, sea turtles, 

candidate ESA coral 

Intact perimeter reef 

(present-day height, 

width, biotic construction) 

and ava (present-day 

depth, width, location 

unblocked flow) that 

regulate seawater 

exchange with 

surrounding ocean and 

seawater flow inside 

lagoon; natural 

breakdown of calcifying 

organisms providing 

carbonate sediment

Proliferation of cyanobacteria; 

illegal fishing and faisua 

poaching; reduced calcification 

linked to ocean acidification
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

F-2 Appendix F. Biological Resources of Concern

Habitats Population/Habitat 

Attributes

Natural Processes 

Responsible for These 

Conditions

Limiting Factors

species

Perimeter 

Crustose 

Coralline 

Algal Reef

Living reef dominated by 

CCA, with intact

geomorphic structure 

providing mosaic of 

microhabitats for 

invertebrates including 

corals and sea urchins

Potential conservation 

species: candidate ESA 

coral species

Growth of CCA and other 

calcifying organisms, and 

accretion of carbonate 

through biochemical 

processes, maintains 

constructional platform 

between open ocean and 

lagoon

Rate of SLR relative to natural 

capacities for growth and 

accretion; reduced calcification 

linked to ocean acidification;

overgrowth by non-reefbuilding cyanobacteria

Ava Unobstructed channel 

between lagoon and fore 

reef with present-day 

depth, width, and location

Potential conservation 

species: faisua, sea turtles, 

candidate ESA coral 

species

Natural hydrological 

regimes of oceanic and 

lagoonal seawater flow

Impedance of natural flow 

patterns by boat grounding or 

other obstacles

Beach 

Strand

Beach strand habitat clear 

of invasive introduced 

plants and marine debris 

that provides nesting sites 

for ground-nesting seabirds 

and turtles and foraging 

sites for migratory 

shorebirds

Sand and rubble formed 

by the action of storms 

and bio-erosion of living 

CCA reef community is 

deposited and re-arranged 

by ocean waves. Plant 

community on the beach 

strand areas are kept at 

seral stage by repeated 

overwashing and storms.

Current sea level

Nonnative invasive species of 

plants and animals; human 

disturbance and trampling; 

interruption in the supply of 

gastropod shells from the reef 

that are used by land hermit 

crabs; sea level rise; reduced 

calcification linked to ocean 

acidification; increased storm 

frequency and intensity 

changing sediment distribution 

patterns

Littoral 

Forest

South Central tropical 

Pacific littoral forest with a 

native species composition 

typical of other intact 

habitats of similar rainfall 

and soil type. This forest 

provides nesting sites for 

arboreal and groundnesting seabirds as well as 

native land crabs, insects, 

and migratory shorebirds

Nutrient input from 

seabird guano and 

precipitation favor pu’a 

vai and other species of 

plants dispersed by birds 

or ocean currents

Nonnative invasive species of 

plants, animals, and pathogens, 

human disturbance; SLR; 

reduced calcification linked to 

ocean acidification; increased 

storm frequency and intensity; 

changing sediment distribution 

patterns
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix F. Biological Resources of Concern F-3

Table F-2. Priority Resources of Concern

Focal Species Habitat Type Habitat Structure Life History 

Requirements

Other Benefiting 

Species

Pu’a vai 

(Pisonia)

Littoral Forest Sandy and 

phosphate soils 

with elevation 

sufficient to avoid 

overwashing in all 

but the largest 

storms (> 6.6 feet)

All Tree-nesting seabirds 

fua’o (red-footed 

booby), atafa (lesser 

frigatebird), atafa 

(great frigatebird), 

gogo (black noddy), 

white tern (manu sina)

Littoral forest 

tree species –

Cordia 

subcordata, 

Tournefortia 

argentea, 

Hernandia 

nymphaeifolia, 

Terminalia 

samoensis, 

Neisosperma 

oppositifolium, 

and Hibiscus 

tiliaceus

Littoral forest

(mesic)

Sandy and 

phosphate soils 

with elevation 

sufficient to avoid 

overwashing in all 

but the largest 

storms (> 6.6 feet)

All Matu’u (Pacific reef 

heron) for nesting 

habitat and aleva

(long-tailed cuckoo) 

for wintering, molting, 

and foraging

Tava’e’ula 

(red-tailed 

tropicbird) 

Littoral forest Ground under 

vegetation in 

understory and 

base of trees; sites 

that provide 

adequate shade for 

nestling for the 

duration of the 

growth period

Nesting Gogo (brown noddy), 

fua’o (brown booby)

Fua’o (redfooted booby)Littoral forest Tournefortia and 

Pisonia trees that 

provide appropriate 

structure for nest 

construction above 

the ground

Nesting Atafa (lesser 

frigatebird), atafa 

(great frigatebird), 

gogo (black noddy)

Land hermit 

crabs 

Coenobita 

perlatus and 

Coenobita 

brevimanus

Littoral forest Sandy and 

phosphate soils, 

vegetation and 

shade protection 

from tropical sun

Reproduction –

aquatic larvae, 

terrestrial adults, 

foraging, proximity 

to sea water source 

for osmoregulation 

and gill maintenance

Tuli prey upon land 

hermit crabs.

Entire forest 

community benefits 

from Coenobita acting 

as scavengers and 

nutrient recyclers
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

F-4 Appendix F. Biological Resources of Concern

Focal Species Habitat Type Habitat Structure Life History 

Requirements

Other Benefiting 

Species

Gogo uli 

(sooty tern)

Beach strand 

and littoral 

forest

Open beach habitat 

or forest sites with 

minimal understory 

that provide open 

access for landing 

and takeoff and 

visibility for these 

highly social 

nesters

Nesting Gogosina (graybacked tern), gogosina 

(black-naped tern), 

bristle-thighed 

curlews, ruddy 

turnstones that prey on 

sooty tern eggs

Tuli (bristlethighed 

curlew)

Beach strand

and littoral 

forest

Open beach habitat 

or open forest

Wintering, molting, 

feeding

Tuli (ruddy turnstone), 

tuli (sanderling), tuli 

(wandering tattler), 

tuli (whimbrel), tuli 

(Pacific golden 

plover)

I’a sa (green 

turtle) and 

laumei uga 

(hawksbill 

turtle)

Beach 

strand/littoral 

forest/lagoon

Sand with access to 

the water but above 

the high tide line

Nesting (i’a sa only), 

resting, feeding

Tamole 

(yellow 

purslane, 

Portulaca 

lutea)

Beach strand Open sand, no over 

story

All

Malie (gray 

reef shark) 

Lagoon, ava Pinnacles, patch 

reefs, back reefs

All Malie alamata 

(blacktip reef shark), 

whitetip reef shark 

(Triaenodon obesus), 

bumphead parrotfish,

Maori wrasse, gatalauli (peacock grouper),

leopard grouper, coral 

hind, strawberry 

grouper, mata’ele

(flagtail grouper),

honeycomb grouper,

gatala-aloalo (dwarf 

spotted grouper),

masked grouper
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix F. Biological Resources of Concern F-5

Focal Species Habitat Type Habitat Structure Life History 

Requirements

Other Benefiting 

Species

Amu (stony 

corals)

Acropora, 

Astreopora, 

Cyphastrea, 

Favia, 

Leptastrea, 

Montastrea, 

Montipora, 

Pavona, 

Platygyra, 

Porites, 

Psammocora, 

Stylocoeniella

spp.

Reef crest, 

back reef, 

lagoon 

pinnacles and 

patch reefs

Hard substrate, 

depth and water 

clarity sufficient 

for light 

penetration, 

moderate 

temperatures, 

seawater 

immersion time 

sufficient to 

prevent 

desiccation, low 

nutrients, low algae 

and cyanobacteria, 

herbivorous fish 

and invertebrates

All (growth, feeding 

(endosymbiosis, and 

plankton capture), 

reproduction)

Reef fish; other 

benthic invertebrates 

(soft corals, mollusks, 

crustaceans, worms, 

echinoderms, 

tunicates)

Faisua (giant 

clam) 

(Tridacna 

maxima)

Lagoon 

pinnacles and 

patch reefs

Hard substrate, 

water depth and 

clarity sufficient 

for light 

penetration 

All (growth, feeding 

(endosymbiosis, and 

filter-feeding), 

reproduction

Sea urchins 

(tuitui)

Reef crest, 

back reef, 

lagoon 

pinnacles and 

patch reefs

Hard substrate, 

available holes for 

occupancy, algal 

films and turf for 

grazing

All (growth, grazing, 

reproduction)

Corals, CCA

Turban shells 

(Turbo 

crassus, Turbo 

setosus, Turbo 

argyrostomus)

Reef and 

lagoon habitats

CCA reef flats with 

epilithic algae for 

grazing

Foraging (herbivores 

and detritus feeders)

Land hermit crabs 

(Coenobita perlatus

and C. brevimanus) 

that use shells of these 

gastropods

Crustose 

coralline algae

(Porolithon 

spp., 

Hydrolithon

spp.)

Reef Hard substrate, 

moderate 

temperatures, low 

cyanobacteria, 

herbivorous fish 

and invertebrates

All (growth, 

photosynthesis, 

reproduction)

Stony corals
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

F-6 Appendix F. Biological Resources of Concern
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix G. Integrated Pest Management Program G-1

Appendix G. Integrated Pest Management (IPM) Program

G.1 Background 

IPM is an interdisciplinary approach utilizing methods to prevent, eliminate, contain, and/or control pest 

species in concert with other management activities on refuge lands and waters to achieve wildlife and 

habitat management goals and objectives. IPM is also a scientifically based, adaptive management 

process where available scientific information and best professional judgment of the refuge staff as well 

as other resource experts will 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 will be particularly 

relevant where long-term impacts may be uncertain and future monitoring will 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, will be selected that are feasible, efficacious, and most protective 

of non-target resources, including native species (fish, wildlife, and plants), and Service personnel, 

Service authorized agents, volunteers, and the public. Staff time and available funding will be considered 

when determining feasibility/practicality of various treatments.

IPM techniques to address pests are presented as CCP strategies (see Chapter 2 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 (environmental consequences) 

presented in Chapter 6 of the Rose Atoll National Wildlife Refuge Draft CCP/EA. 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. However, the basic framework to assess potential effects to refuge 

biological resources and environmental quality from aerial application of pesticides would be similar to 

the process described in this Appendix for ground-based treatments of other pesticides. 

G.2 Pest Management Laws and Policies

In accordance with Service policy 569 FW 1 (Integrated Pest Management), plant, invertebrate, and 

vertebrate pests on units of the National Wildlife Refuge System can be controlled to ensure 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:
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

G-2 Appendix G. Integrated Pest Management Program

• National Wildlife Refuge System Administration Act of 1966, as amended (16 USC 668dd-668ee); 

• 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 purpose(s) for which the 

refuge was established.

The specific justifications for pest management activities on the refuge are the following:

• Protect human health and well being;

• Prevent substantial damage to important to refuge resources;

• Protect newly introduced or re-establish native species;

• Control nonnative (exotic) species in order to support existence for populations of native species;

• 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 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix G. Integrated Pest Management Program G-3

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). For 

example, on the mainland, the incidental removal of beaver damaging refuge infrastructure (e.g., clogging 

with subsequent damaging of water control structures) and/or negatively affecting habitats (e.g., removing 

woody species from existing or restored riparian areas) managed on refuge lands may be conducted 

without a pest control proposal. Exotic nutria, whose denning and burrowing activities in wetland dikes 

causes cave-ins and breaches, can be controlled using the most effective techniques considering sitespecific factors without a pest control proposal. Along with the loss of quality wetland habitats associated 

with breaching of impoundments, the safety of refuge staff and public (e.g., auto tour routes) driving on 

structurally compromised levees and dikes can be threatened by sudden and unexpected cave-ins.

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]).

G.3 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 to determine 

if current management activities on a refuge may introduce and/or spread invasive species in order to 

identify appropriate BMPs for prevention. See http://www.haccp-nrm.org/ for more information about 

HACCP planning.

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 re-introductions by 

various mechanisms including vehicles, personnel, livestock, and horses. Because invasive species 

are frequently the first to establish newly disturbed sites, prevention would require a reporting 

mechanism for early detection of new pest occurrences with quick response to eliminate any new 

satellite pest populations. Prevention would require consideration of the scale and scope of land 

management activities that may promote pest establishment within un-infested areas or promote 

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 for 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.
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

G-4 Appendix G. Integrated Pest Management Program

The following would be methods to prevent the introduction and/or spread of pests on refuge lands:

o 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, the refuge staff would begin project activities in un-infested areas before 

working in pest-infested areas.

o The 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.

o The refuge staff would determine the need for, and when appropriate, identify sanitation sites 

where equipment can be cleaned of pests. Where possible, the 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.

The refuge staff would remove mud, dirt, and plant parts from project equipment before 

moving it into a project area. 

o The refuge staff would clean all equipment, before leaving the project site, if operating in 

areas infested with pests. The refuge staff would determine the need for, and when 

appropriate, identify sanitation sites where equipment can be cleaned.

o Refuge staff, 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).

o The refuge staff would evaluate options, including closure, to restrict the traffic on sites with 

on-going restoration of desired vegetation. The 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. The refuge staff would use native material, where 

appropriate and feasible. The refuge staff would use certified weed-free or weed-seed-free 

hay or straw where certified materials are reasonably available. 

o The refuge staff would provide information, training, and appropriate pest identification 

materials to permit holders and recreational visitors. The refuge staff would educate them 

about pest identification, biology, impacts, and effective prevention measures.

o The refuge staff would require grazing permittees to utilize preventative measures for their 

livestock while on refuge lands.

o The refuge staff would inspect borrow material for invasive plants prior to use and transport 

onto and/or within refuge lands. 

o The refuge staff would consider invasive plants in planning for road maintenance activities.

o The 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: 

o The refuge staff would inspect boats (including air boats), trailers, and other boating 

equipment. Where possible, the refuge staff would remove any visible plants, animals, or 

mud before leaving any waters or boat launching facilities. Where possible, the refuge staff 

would drain water from motor, live well, bilge, and transom wells while on land before

leaving the site. 

o If possible, the 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. 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix G. Integrated Pest Management Program G-5

o Where feasible, the refuge staff would maintain a 100-foot buffer of aquatic pest-free 

clearance around boat launches and docks or quarantine areas when cleaning around culverts, 

canals, or irrigation sites. Where possible, the refuge staff would inspect and clean equipment 

before moving to new sites or one project area to another.

These prevention methods to minimize/eliminate the introduction and/or spread of pests were taken 

verbatim or slightly modified from Appendix E of USFS (2005).

• Mechanical/Physical Methods. These methods would remove and destroy, disrupt the growth of, or 

interfere with the reproduction of pest species. For plants species, these treatments can be 

accomplished by hand, hand tool (manual), or power tools (mechanical) and include pulling, 

grubbing, digging, tilling/disking, cutting, swathing, grinding, shearing, girdling, mowing, and 

mulching of the pest plants.

For animal species, Service employees or their authorized agents could use mechanical/physical 

methods (including trapping) to control pests as a refuge management activity. Based upon 50 CFR 

31.2, trapping can be used on a refuge to reduce surplus wildlife populations for a “balanced 

conservation program” in accordance with Federal or state laws and regulations. In some cases, nonlethally trapped animals would be relocated to off-refuge sites with prior approval from the state.

Each of these tools would be efficacious to some degree and applicable to specific situations. In 

general, mechanical controls can effectively control annual and biennial pest plants. However, to 

control perennial plants, the root system has to be destroyed or it would resprout and continue to grow 

and develop. Mechanical controls are typically not capable of destroying a perennial plant’s 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, 

mulching, winter cover crops, changing planting dates to minimize pest impact, prescribed burning 

(facilitate revegetation, increase herbicide efficacy, and remove litter to assist in emergence of 

desirable species), flaming with propane torches, trap crops, crop rotations that would include nonsusceptible crops, moisture management, addition of beneficial insect habitat, reducing clutter, proper 

trash disposal, planting or seeding desirable species to shade or out-compete invasive plants, applying 

fertilizer to enhance desirable vegetation, prescriptive grazing, and other habitat alterations. 

• Biological Control Agents. Classical biological control would involve the deliberate introduction 

and management of natural enemies (parasites, predators, or pathogens) to reduce pest populations.

Many of the most ecologically or economically damaging pest species in the United States originated 

in foreign countries. These newly introduced pests, which are free from 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 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

G-6 Appendix G. Integrated Pest Management Program

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 (the most common group). Often it 

is assumed that biological control would address many if not most of these pest problems. There are 

several well-documented success stories of biological control of invasive weed species in the Pacific 

Northwest including Mediterranean sage, St. Johnswort (Klamath weed) and tansy ragwort. Emerging 

success stories include Dalmatian toadflax, diffuse knapweed, leafy spurge, purple loosestrife, and 

yellow star thistle. However, historically, each new introduction of a biological control agent in the 

United States has only about a 30% success rate (Coombs et al. 2004). Refer to Coombs et al. (2004) 

for the status of biological control agents for invasive plants.

Introduced species without desirable close relatives in the United States would generally be selected 

as biological controls. Natural enemies that are restricted to one or a few closely related plants in their 

country of origin are targeted as biological controls (Center et al. 1997, Hasan and Ayres 1990).

The refuge staff would ensure introduced agents are approved by the applicable authorities. Except 

for a small number of formulated biological control products registered by EPA 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 biocontrols agents from 

another state. Form 526 may be obtained by writing:
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix G. Integrated Pest Management Program G-7

USDA-APHIS-PPQ

Biological Assessment and Taxonomic Support

4700 River Road, Unit 113

Riverdale, MD 20737

Or through the internet at 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 non-indigenous 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 7 RM 8 (Exotic Species Introduction and Management). In 

addition, the 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:

o Release only approved biological control agents;

o Use the most effective agents;

o Document releases; and

o Monitor for impact to the target pest species, non-target 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. 

The NEPA documents regarding biological and other environmental effects of biological control 

agents prepared by another federal agency, where the scope is relevant to evaluation of releases on 

refuge lands, would be reviewed. Possible source agencies for such NEPA documents include the 

Bureau of Land Management, U.S. Forest Service, National Park Service, U.S. Department of 

Agriculture-Animal and Plant Health Inspection Service, and the military services. It might be 

appropriate to incorporate by reference parts or all of existing document(s) from the review. 

Incorporating by reference (43 CFR 46.135) is a technique used to avoid redundancies in analysis. It 

also can reduce the bulk of a Service NEPA document, which only must identify the documents that 

are incorporated by reference. In addition, relevant portions must be summarized in the Service 

NEPA document to the extent necessary to provide the decision maker and public with an

understanding of relevance of the referenced material to the current analysis. 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

G-8 Appendix G. Integrated Pest Management Program

• 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 non-target 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. The 

PUP records would provide a detailed, time-, site-, and target-specific description of the proposed use 

of pesticides on the 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 non-target areas and degradation of 

surface and groundwater quality. Where possible, target-specific equipment (e.g., backpack sprayer, 

wiper) would be used to treat target pests. Other target-specific equipment to apply pesticides would 

include soaked wicks or paint brushes for wiping vegetation and lances, hatchets, or syringes for 

direct injection into stems. Granular pesticides may be applied using seeders or other specialized 

dispensers. In contrast, aerial spraying (e.g., fixed wing or helicopter) would only be used where 

access is difficult (remoteness) and/or the size/distribution of infestations precludes practical use of 

ground-based methods.

Because repeated use of one pesticide may allow resistant organisms to survive and reproduce, 

multiple pesticides with variable modes of action would be considered for treatments on refuge lands 

and waters. This is especially important if multiple applications within years and/or over a growing 

season likely would be necessary for habitat maintenance and restoration activities to achieve 

resource objectives. Integrated chemical and non-chemical 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 a 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 Sheley 2001, Brooks et 

al. 2004). The following three components of succession could be manipulated through habitat 

maintenance and restoration: site availability, species availability, and species performance (Cox and 

Anderson 2004). Although a single method (e.g., herbicide treatment) may eliminate or suppress pest 

species in the short term, the resulting gaps and bare soil create niches that are conducive to further 

invasion by the species and/or other invasive plants. On degraded sites where desirable species are 

absent or in low abundance, revegetation with native/desirable grasses, forbs, and legumes may be 

necessary to direct and accelerate plant community recovery, and achieve site-specific objectives in a 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix G. Integrated Pest Management Program G-9

reasonable time frame. The selection of appropriate species for revegetation would be dependent on a 

number of factors including resource objectives and site-specific, abiotic factors (e.g., soil texture, 

precipitation/temperature regimes, and shade conditions). Seed availability and cost, ease of 

establishment, seed production, and competitive ability also would be important considerations.

G.4 Priorities for Treatments

For many refuges, the magnitude (number, distribution, and sizes of infestations) of pest problems is too 

extensive and beyond the available capital resources to effectively address during any single field season.

To manage pests on the 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), NWRS 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 un-infested 

areas. Moody and Mack (1988) demonstrated through modeling that small, new outbreaks of invasive 

plants eventually would infest an area larger than the established, source population. They also found that 

control efforts focusing on the large, main infestation rather than the new, small satellites reduced the 

chances of overall success. The lowest priority would be treating large infestations (sometimes monotypic 

stands) of well-established pests. In this case, initial efforts would focus upon containment of the 

perimeter followed by work to control/eradicate the established infested area. If containment and/or 

control of a large infestation is not effective, then efforts would focus upon halting pest reproduction or 

managing source populations. Maxwell et al. (2009) found treating fewer populations that are sources 

represents an effective long-term strategy to reduce of total number of invasive populations and 

decreasing meta-population growth rates.

Although state-listed noxious weeds would always be of high priority for management, other pest species 

known to cause substantial ecological impact would also be considered. For example, cheatgrass may not 

be listed by a state as noxious, but it can greatly alter fire regimes in shrub steppe habitats resulting in 

large monotypic stands that displace native bunch grasses, forbs, and shrubs. Pest control would likely 

require a multi-year commitment from the 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.

G.5 Best Management Practices (BMPs)

The BMPs can minimize or eliminate possible effects associated with pesticide usage to non-target 

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

Integrated Pest Management policy (569 FW 1), 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 target- and 

site-specific factors and time-specific environmental conditions. Although not listed below, the most 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

G-10 Appendix G. Integrated Pest Management Program

important BMP to eliminate/reduce potential impacts to non-target resources would be an IPM approach 

to prevent, control, eradicate, and contain pests.

G.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.

• The refuge staff would triple rinse and recycle (where feasible) pesticide containers.

• All unused pesticides would be properly discarded at a local “safe send” collection.

• Pesticides and pesticide containers would be lawfully stored, handled, and disposed of in accordance 

with the label and in a manner safeguarding human health, fish, and wildlife and prevent soil and 

water contaminant.

• The 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 the refuge spill 

response plan.

G.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 Bureau of Land Management certification to 

safely and effectively conduct these activities on refuge lands and waters.

• The refuge staff would comply with all federal, state, and local pesticide use laws and regulations as 

well as Departmental, Service, and Refuge System pesticide-related policies. For example, the 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 PUPs for each pesticide, determining the 

target pest, appropriate mix rate(s), PPE, and other requirements listed on the pesticide label.

• A 1-foot no-spray buffer from the water’s edge would be used, where applicable, and where 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 <7 mph and preferably 3-5 mph) and 

consistent direction wind conditions with moderate temperatures (typically <85o

F). 

• 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 non-target areas.
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix G. Integrated Pest Management Program G-11

• 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 non-toxic dye to aid in identifying target area treated as well 

as potential over spray or drift. A dye can also aid in detecting equipment leaks. If a leak is 

discovered, the application would be stopped until repairs can be made to the sprayer.

• For pesticide uses associated with cropland and 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. The 

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.

• The 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, all-terrain vehicle, tractor) would be thoroughly cleaned and 

personal protective equipment (PPE) would be removed/disposed of on-site by applicators after 

treatments to eliminate the potential spread of pests to un-infested areas.

G.6 Safety

G.6.1 Personal Protective Equipment

All applicators would wear the specific PPE identified on the pesticide label. The appropriate PPE would

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 NIOSHapproved 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 would

be consistent with label requirements, EPA 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.
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

G-12 Appendix G. Integrated Pest Management Program

G.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. The refuge staff would also notify appropriate private 

property owners of an intended application, including any private individuals who have requested 

notification. Special efforts would be made to contact nearby individuals who are beekeepers or who have 

expressed chemical sensitivities.

G.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 one 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 FW 7.7A, “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 G.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 (e.g., cooperative farmers) 

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.

G.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 (BLM) licensed to apply 

pesticides to refuge lands or waters. In accordance with 242 FW 7.18A and 569 FW 1.10B, certification is 

required to apply restricted use pesticides based upon EPA 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. 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix G. Integrated Pest Management Program G-13

G.6.5 Record Keeping

G.6.5.1 Labels and material safety data sheets

Pesticide labels and material safety data sheets (MSDSs) would be maintained at the refuge shop and 

laminated copies in the mixing area. These documents also would be carried by field applicators, where 

possible. A written reference (e.g., note pad, chalk board, dry erase board) for each tank to be mixed 

would be kept in the mixing area for quick reference while mixing is in progress. In addition, approved 

PUPs stored in the PUPS database typically contain website links (URLs) to pesticide labels and MSDSs.

G.6.5.2 Pesticide use proposals (PUPs)

A PUP would be prepared for each proposed pesticide use associated with annual pest management on 

refuge lands and waters. A PUP would include specific information about the proposed pesticide use 

including the common and chemical names of the pesticide(s), target pest species, size and location of 

treatment site(s), application rate(s) and method(s), and federally listed species determinations, where 

applicable.

In accordance with 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 habitat management plan (HMP)

if IPM strategies and potential environmental effects are adequately addressed within appropriate NEPA 

documentation.

The 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.

G.6.5.3 Pesticide usage 

In accordance with 569 FW 1, the refuge project leader would be required to maintain records of all 

pesticides annually applied on lands or waters under refuge jurisdiction. This would encompass pesticides 

applied by other Federal agencies, state and county governments, non-government applicators including 

cooperators and their pest management service providers with Service permission. For clarification, 

pesticide means all insecticides, insect and plant growth regulators, desiccants, 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); and

• Efficacy (% control).

To determine whether treatments are efficacious (eradicating, controlling, or containing the target pest) 

and achieving resource objectives, habitat and/or wildlife response would be monitored both pre- and 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

G-14 Appendix G. Integrated Pest Management Program

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 infestationdensity, % 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) 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.

G.7 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 non-listed 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 G.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 G.4) for habitat 

management and cropland/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.

G.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 doseresponse 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 USEPA (2004). Assumptions for these risk assessments are presented in 

Section G.7.2.3.

The toxicological data used in ecological risk assessments are typically results of standardized laboratory 

studies provided by pesticide registrants to the EPA to meet regulatory requirements under the Federal 

Insecticide, Fungicide and Rodenticide Act of 1996 (FIFRA). These studies assess the acute (lethality) 

and chronic (reproductive) effects associated with short- and long-term exposure to pesticides on 

representative species of birds, mammals, freshwater fish, aquatic invertebrates, and terrestrial and 

aquatic plants. Other effects data publicly available would also be utilized for risk assessment protocols 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix G. Integrated Pest Management Program G-15

described herein. Toxicity endpoint and environmental fate data are available from a variety of resources. 

Some of the more useful resources can be found at the end of Section G.7.5.

Table G-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.

G.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 EPA’s Ecological Risk Assessment Process (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 Refuge System. 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 G-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 EPA (1998b) (Table G-2). The 

LOC represents a quantitative threshold value for screening potential adverse effects to fish and wildlife 

resources associated with pesticide use. The following are four exposure-species group scenarios that 

would be used to characterize ecological risk to fish and wildlife on the Refuge: acute-listed species, 

acute-nonlisted species, chronic-listed species, and chronic-nonlisted species.

Acute risk would indicate the potential for mortality associated with short-term dietary exposure to 

pesticides immediately after an application. For characterization of acute risks, median values from LC50

and LD50 tests would be used as toxicological endpoints for RQ calculations. In contrast, chronic risks 

would indicate the potential for adverse effects associated with long-term dietary exposure to pesticides 

from a single application or multiple applications over time (within a season and over years). For 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

G-16 Appendix G. Integrated Pest Management Program

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 affect” individuals (listed species) and it would not pose an 

unacceptable risk for adverse effects to populations (non-listed species) for each taxonomic group (Table 

G-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 G-2. Presumption of Unacceptable Risk for Birds, Fish, and Mammals (USEPA 1998b)

Risk Presumption

Level of Concern

Listed Species Non-listed 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

G.7.2.1 Environmental exposure 

Following release into the environment through application, pesticides would experience several different 

routes of environmental fate. Pesticides which would be sprayed can move through the air (e.g., particle 

or vapor drift) and may eventually end up in other parts of the environment such as non-target 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 1993). 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). 

G.7.2.1.1 Terrestrial exposure

The estimated environmental concentration (ECC) for exposure to terrestrial wildlife would be quantified 

using an USEPA screening-level approach (USEPA 2004). This screening-level approach is not affected 

by product formulation because it evaluates pesticide active ingredient(s). This approach would vary 

depending upon the proposed pesticide application method: spray or granular.
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix G. Integrated Pest Management Program G-17

G.7.2.1.1.1 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 (TREX) version 1.2.3 (USEPA 2005b). To estimate the maximum (initial) pesticide residue on short grass 

(<20 cm 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 worst-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 T-REX 

by default, but body weights of other organisms (Table G-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 T-REX Kanaga nomogram would 

be used as an EEC for calculation of RQs. This approach would yield a conservative estimate of 

ecological risk. 

Table G-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 (1,000 g) 1.000

Mallard 1.082

Ring-necked pheasant 1.135
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

G-18 Appendix G. Integrated Pest Management Program

G.7.2.1.1.2 Terrestrial – granular application

Granular pesticide formulations and pesticide-treated seed would pose a unique route of exposure for 

avian and mammalian species. The pesticide is applied in discrete units which birds or mammals 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 (a.i.) 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 G-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 1998b). 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 would 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/1,000 ft. row)(% a.i.)(1,000 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, and seeds are unincorporated. 

mg a.i./ft.

2 

= [(lbs. product/1,000 row ft.)(% a.i.)(453,580 mg/lb.)(1-% incorporated)] / (1,000 ft.)(band 

width (ft.)) 

EEC = [(mg a.i./ft.

2

)(% of pesticide biologically available)] 

• Broadcast treatment without incorporation assumes 100% of granules, bait, seeds are unincorporated. 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix G. Integrated Pest Management Program G-19

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 be used to calculate an RQ based on the EEC calculated by one of the 

above equations. The EEC would be divided by the surrogate LD50 toxicological endpoint multiplied by 

the body weight (Table G-3) of the surrogate. 

RQ = EEC / [LD50 (mg/kg) * body weight (kg)] 

As with other risk assessments, an RQ>LOC would be a presumption of unacceptable ecological risk. An

RQ<LOC would be a presumption of acceptable risk with only minor, temporary, or localized effects to 

species. 

G.7.2.1.2 Aquatic exposure

Exposures to aquatic habitats (e.g., wetlands, meadows, ephemeral pools, water delivery ditches) would 

be evaluated separately for ground-based pesticide treatments of habitats managed for fish and wildlife 

compared with cropland/facilities maintenance. The primary exposure pathway for aquatic organisms 

from any ground-based treatments likely would be particle drift during the pesticide application.

However, different exposure scenarios would be necessary as a result of contrasting application 

equipment and techniques as well as pesticides used to control pests on agricultural lands (especially 

those cultivated by cooperative farmers for economic return from crop yields) 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 feet of the high water mark of aquatic habitats for habitat 

management treatments; whereas, no-spray buffers (≥25 feet) would be used for croplands/facilities 

maintenance treatments.

G.7.2.1.2.1 Habitat treatments

For the worst-case exposure scenario to non-target aquatic habitats, EECs (Table G-4) would be would be 

derived from Urban and Cook (1986) that assumes an intentional overspray to an entire, non-target water 

body (1-foot depth) from a treatment <25 feet from the high water mark using the max application rate 

(acid basis [see above]). However, use of BMPs for applying pesticides (see Section G.4.2) would likely 

minimize/eliminate potential drift to non-target 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).
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

G-20 Appendix G. Integrated Pest Management Program

Table G-4. Estimated Environmental Concentrations (ppb) of Pesticides in Aquatic Habitats (1 foot 

depth) Immediately after Direct Application (Urban and Cook 1986)

Lbs/acre EEC (ppb)

0.10 36.7

0.20 73.5

0.25 91.9

0.30 110.2

0.40 147.0

0.50 183.7

0.75 275.6

1.00 367.5

1.25 459.7

1.50 551.6

1.75 643.5

2.00 735.7

2.25 827.6

2.50 919.4

3.00 1,103.5

4.00 1,471.4

5.00 1,839

6.00 2,207

7.00 2,575

8.00 2,943

9.00 3,311

10.00 3,678

G.7.2.1.2.2 Cropland/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 feet 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 inches), 

fine to medium droplet size, EPA-defined wetland, and a ≥25-foot distance (buffer) from treated area to 

water. 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix G. Integrated Pest Management Program G-21

G.7.2.2 Use of information on effects of biological control agents, pesticides, degradates, and 

adjuvants

NEPA documents regarding biological and other environmental effects of biological control agents, 

pesticides, degradates, and adjuvants prepared by another federal agency, where the scope would be 

relevant to evaluation of effects from pesticide uses on refuge lands, would be reviewed. Possible source 

agencies for such NEPA documents would include the Bureau of Land Management, 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). 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 U.S. Forest Service 

(http://www.fs.fed.us/r6/invasiveplant-eis/Risk-Assessments/Herbicides-Analyzed-InvPlant-EIS.htm) and 

Bureau of Land Management (http://www.blm.gov/wo/st/en/prog/more/veg_eis.html). These risk 

assessments and associated documentation also are available in total with the administrative record for the 

Final Environmental Impact Statement entitled Pacific Northwest Region Invasive Plant Program –

Preventing and Managing Invasive Plants (USFS 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 U.S. Forest Service would be 

incorporated by reference:

• 2,4-D;

• Chlorsulfuron;

• Clopyralid;

• Dicamba;

• Glyphosate;

• Imazapic;

• Imazapyr;

• Metsulfuron methyl;

• Picloram;

• Sethoxydim;

• Sulfometuron methyl;

• Triclopyr; and

• 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 Bureau of Land Management would be incorporated by 

reference:
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G-22 Appendix G. Integrated Pest Management Program

• Bromacil;

• Chlorsulfuron;

• Diflufenzopyr;

• Diquat;

• Diuron;

• Fluridone;

• Imazapic;

• Overdrive (diflufenzopyr and dicamba);

• Sulfometuron methyl;

• Tebuthiuron;

• Pesticide degradates and adjuvants (Appendix D – Evaluation of risks from degradates,

polyoxyethylene-amine (POEA) and R-11, and endocrine disrupting chemicals).

G.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. Non-target 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 are 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 would 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-weighted-average 

(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 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix G. Integrated Pest Management Program G-23

nomogram represents the maximum expected instantaneous or acute exposure to a pesticide. Acute 

toxicity endpoints are determined using a single exposure to a known pesticide concentration 

typically for 48 to 96 hours. This value is assumed to represent ecological risk from acute exposure to 

a pesticide. On the other hand, chronic risk to pesticide exposure is a function of pesticide 

concentration and duration of exposure to the pesticide. An organism’s response to chronic pesticide 

exposure may result from either the concentration of the pesticide, length of exposure, or some 

combination of both factors. Standardized tests for chronic toxicity typically involve exposing an 

organism to several different pesticide concentrations for a specified length of time (days, weeks, 

months, years, or generations). For example, avian reproduction tests include a 10-week exposure 

phase. Because a single length of time is used in the test, time response data are 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 would 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 TREX 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 would require justification and it would 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, these data are 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 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 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

G-24 Appendix G. Integrated Pest Management Program

concentrations in soil compared to food item categories in the Kanaga nomogram indicates incidental 

soil ingestion would 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 of 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 foliar-applied 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 near-field 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 would 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 the potential to dissolve in surface runoff and puddles in a 

treated area may contain pesticide residues. Similarly, pesticides with lower organic carbon 

partitioning characteristics and higher solubility in water have a greater potential to dissolve in dew 

and other water associated with plant surfaces. Estimating the extent to which such pesticide loadings 

to drinking water occurs is complex and would depend upon the partitioning characteristics of the 

active ingredient, soils types in the treatment area, and the meteorology of the treatment area. In 

addition, the use of various water sources by wildlife is highly species-specific. 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 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix G. Integrated Pest Management Program G-25

formally established by the USEPA for assessing exposure to pesticides through drinking water, these 

protocols would 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 tends 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.

• There are several other assumptions that can affect non-target 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 effects to 

non-target 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 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

G-26 Appendix G. Integrated Pest Management Program

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 water-borne concentration. However, this 

assumption would not account for the 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-bycase 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 non-target 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 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix G. Integrated Pest Management Program G-27

may exist at some level contributing to adverse effects to non-target 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. 

G.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. 

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 

non-target 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 non-target 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 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

G-28 Appendix G. Integrated Pest Management Program

effects (additive or synergistic) from chemical mixtures that typically rely upon broadly encompassing 

assumptions. For example, the USFS (2005) found that mixtures of pesticides used in land (forest) 

management likely would not cause additive or synergistic effects to non-target 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 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.

A USEPA-approved label specifies whether a product can be mixed with one or more pesticides. Without 

product-specific toxicological data, it would not be 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.
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix G. Integrated Pest Management Program G-29

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.

G.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 runoff or wind;

• Dissolve in water that can be subjected to runoff or leaching. 

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: non-persistent <30 days, moderately persistent = 30 to 100 days, and persistent >100 days 

(Kerle et al. 1996). Half-life data are 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 are not available, soil half-life data may be used. The average or representative half-life 

value of most important degradation mechanism would 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. 
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G-30 Appendix G. Integrated Pest Management Program

Water solubility describes the amount of pesticide that would 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 

parts per millions [ppm]). Pesticide with solubility <0.1 ppm are virtually insoluble in water, 100-1,000 

ppm are moderately soluble, and >10,000 ppm highly soluble (USGS 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) × [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.

Water solubility describes the amount of pesticide dissolving in a specific quantity of water, where it is 

usually measured as mg/l or ppm. Solubility is useful as a comparative measure because pesticides with 

higher values are more likely to move by runoff 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 affects pesticide 

degradation. 
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Appendix G. Integrated Pest Management Program G-31

• Soil pH would influence chemical reactions that occur in the soil which in turn determines whether or 

not a pesticide would 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 well-drained 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 non-target biota and protecting environmental quality.

Along with soil properties, the potential for a pesticide to affect water quality through runoff 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 persists. In some situations, a hard pan exists above the 

water table that would prevent pesticide contamination from leaching. 

G.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.
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G-32 Appendix G. Integrated Pest Management Program

G.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 are available in references” would be recorded in the profile. Available scientific information would 

be used to complete Chemical Profiles. Each entry of scientific information would be shown with 

applicable references.

Completed Chemical Profiles would provide a structured decision-making process utilizing quantitative 

assessment/screening tools with threshold values (where appropriate) that would be used 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 

non-listed species with appropriate BMPs (see Section G.5), 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.
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Appendix G. Integrated Pest Management Program G-33

Pesticide Type: Service personnel would record the type of pesticide for an active ingredient as one of 

the following: herbicide, desiccant, fungicide, fumigant, growth regulator, insecticide, piscicide, or 

rodenticide. 

EPA Registration Number(s): This number (EPA Reg. No.) appears on the title page of the label and 

MSDS, Section 1: Chemical Product and Company Description. It is not the EPA Establishment Number 

that is usually located near it. Service personnel would record the EPA Reg. No. for each trade name 

product with an active ingredient based upon PUPs.

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-toKnow, 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 are available in 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 G-1 in 

Section G.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 G-1 in Section 

G.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 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

G-34 Appendix G. Integrated Pest Management Program

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 

G-1 in Section G.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 G-1 in 

Section G.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 G-1 in Section G.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 G-1 in Section G.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 G-1 in Section G.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 G-1 in Section G.7.1).

Other: For test invertebrate as well as non-vascular and vascular plant species available in the scientific 

literature, Service personnel would record LC50, LD50, LOEC, LOEL, NOAEC, NOAEL, or EC50 

(environmental concentration) values in ppm or mg/L. Most common test invertebrate species available in 

scientific literature are the honey bee and the water flea (Daphnia magna). Green algae (Selenastrum 

capricornutum) and pondweed (Lemna minor) are frequently available test species for aquatic nonvascular and vascular plants, respectively.

Ecological Incident Reports: After a site has been treated with pesticide(s), wildlife may be exposed to 

these chemical(s). When exposure is high relative to the toxicity of the pesticides, wildlife may be killed 

or visibly harmed (incapacitated). Such events are called ecological incidents. The USEPA maintains a 

database (Ecological Incident Information System) of ecological incidents. This database stores 

information extracted from incident reports submitted by various federal and state agencies and nongovernment organizations. Information included in an incident report is date and location of the incident, 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix G. Integrated Pest Management Program G-35

type and magnitude of effects 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 

1,000 ppm, highly soluble >10,000 ppm (USGS 2000). As pesticide Sw increases, there would be greater 

potential to degrade water quality through runoff 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: non-persistent <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 runoff 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 feet and average annual 

precipitation >12 inches.

• 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, 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

G-36 Appendix G. Integrated Pest Management Program

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 are not available, soil half-life data 

would be used in a Chemical Profile. The average or representative half-life 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: non-persistent <30 days, moderately persistent = 30 to 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 runoff 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 feet and average annual 

precipitation >12 inches.

• 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: non-persistent <30 

days, moderately persistent = 30 to 100 days, and persistent >100 days (Kerle et al. 1996).

Threshold for Approving PUPs:

If aquatic t1⁄2 ≤100 days, then a PUP would be approved without additional BMPs to protect water quality.

If aquatic t1⁄2 >100 days, then a PUP would only be approved with additional BMPs specifically to protect 

water quality. One or more BMPs such as the following would be included in the Specific Best 

Management Practices (BMPs) section to minimize potential surface runoff 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 feet and average annual 

precipitation >12 inches.

• 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 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix G. Integrated Pest Management Program G-37

persistence in aquatic habitats also would be categorized as one of the following: non-persistent <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 runoff 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 feet and average annual 

precipitation >12 inches.

• 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 runoff 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 feet and average annual 

precipitation >12 inches.

• 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 off-target 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). 
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G-38 Appendix G. Integrated Pest Management Program

Threshold for Approving PUPs:

If I ≤1,000, then a PUP would be approved without additional BMPs to minimize drift and protect air 

quality.

If I>1,000, 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 >1,000 

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 (USGS 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>1,000 or Sw<1 mg/L and soil t1⁄2>30 

days), then the PUP would not approved, except under unusual circumstances where approval would 

only be granted by the Washington Office.

Bioaccumulation/Bioconcentration: The physiological process where pesticide concentrations in tissue 

would increase in biota because they are taken and stored at a faster rate than they are metabolized or 

excreted. The potential for bioaccumulation would be evaluated through bioaccumulation factors (BAFs) 

or bioconcentration factors (BCFs). Based upon BAF or BCF values, the potential to bioaccumulate 

would be recorded as one of the following: low = 0 to 300; moderate = 300 to 1,000; or high >1,000 

(Calabrese and Baldwin 1993).

Threshold for Approving PUPs:

If BAF or BCF≤1,000, then a PUP would be approved without additional BMPs.

If BAF or BCF>1,000, 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 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix G. Integrated Pest Management Program G-39

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 G.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 inches), fine to medium/coarse droplet size, 20 swaths, EPA-defined wetland, and 

25-foot distance (buffer) from treated area to water.

See Section G.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 G.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 G-2 in Section G.7.2). If a calculated RQ exceeds an established LOC value (in 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

G-40 Appendix G. Integrated Pest Management Program

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 G.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 non-listed 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 feet 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 would 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 non-target 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 

G.4 of this document for a complete list of BMPs associated with mixing and applying pesticides 

appropriate for all PUPs with ground-based treatments that would be additive to any necessary, chemicalspecific 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, U.S. Environmental Protection Agency, 

Washington, D.C. (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) 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix G. Integrated Pest Management Program G-41

4. FAO specifications and evaluations for plant protection products. Pesticide Management Unit, Plant 

Protection Services, Food and Agriculture Organization, United Nations. 

(http://www.fao.org/WAICENT/FAOINFO/AGRICULT/AGP/AGPP/Pesticid/) 

5. Human health and ecological risk assessments. Pesticide Management and Coordination, Forest 

Health Protection, US Department of Agriculture, US Forest Service. 

(http://www.fs.fed.us/foresthealth/pesticide/risk.htm) 

6. Pesticide Chemical Fact Sheets. Clemson University Pesticide Information Center. 

(http://entweb.clemson.edu/pesticid/Document/Labels/factshee.htm) 

7. Pesticide Fact Sheets. Published by Information Ventures, Inc. for Bureau of Land Management, 

Dept. of Interior; Bonneville Power Administration, U.S. Dept. of Energy; and Forest Service, US 

Department of Agriculture. (http://infoventures.com/e-hlth/pesticide/pest-fac.html) 

8. Pesticide Fact Sheets. National Pesticide Information Center. (http://npic.orst.edu/npicfact.htm) 

9. Pesticide Fate Database. US Environmental Protection Agency, Washington, D.C. 

(http://cfpub.epa.gov/pfate/home.cfm)

10. Pesticide product labels and material safety data sheets. Crop Data Management Systems, Inc. 

(CDMS) (http://www.cdms.net/pfa/LUpdateMsg.asp) or multiple websites maintained by 

agrichemical companies. 

11. Registered Pesticide Products (Oregon database). Oregon Department of Agriculture. 

(http://www.oda.state.or.us/dbs/pest_products/search.lasso) 

12. Regulatory notes. Pest Management Regulatory Agency, Health Canada, Ontario, Canada. 

(http://www.hc-sc.gc.ca/pmra-arla/) 

13. Reptile and Amphibian Toxicology Literature. Canadian Wildlife Service, Environment Canada, 

Ontario, Canada. (http://www.cws-scf.ec.gc.ca/nwrc-cnrf/ratl/index_e.cfm) 

14. Specific Chemical Fact Sheet – New Active Ingredients, Biopesticide Fact Sheet and Registration 

Fact Sheet. U.S. Environmental Protection Agency, Washington, D.C. 

(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. US Environmental Protection Agency, Office of Pesticide Programs, 

Washington, D.C. 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

G-42 Appendix G. Integrated Pest Management Program

Chemical Profile

Date:

Trade Name(s): Common Chemical 

Name(s):

Pesticide Type: EPA Registration 

Number:

Pesticide Class: CAS Number:

Other Ingredients:

Toxicological Endpoints

Mammalian LD50:

Mammalian LC50:

Mammalian Reproduction:

Avian LD50:

Avian LC50:

Avian Reproduction:

Fish LC50:

Fish ELS/Life Cycle:

Other:

Ecological Incident Reports

Environmental Fate

Water solubility (Sw):

Soil Mobility (Koc):

Soil Persistence (t1⁄2):

Soil Dissipation (DT50):

Aquatic Persistence (t1⁄2):

Aquatic Dissipation (DT50):

Potential to Move to Groundwater 

(GUS score):

Volatilization (mm Hg):

Octanol-Water Partition Coefficient 

(Kow):

Bioaccumulation/Bioconcentration: 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):
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix G. Integrated Pest Management Program G-43

Habitat Management Treatments:

Presumption of Unacceptable Risk Risk Quotient (RQ)

Listed (T&E) 

Species

Nonlisted Species

Acute Birds [0.1] [0.5]

Mammals [0.1] [0.5]

Fish [0.05] [0.5]

Chronic Birds [1] [1]

Mammals [1] [1]

Fish [1] [1]

Cropland/Facilities Maintenance Treatments:

Presumption of Unacceptable Risk Risk Quotient (RQ)

Listed (T&E) 

Species Nonlisted Species

Acute Birds [0.1] [0.5]

Mammals [0.1] [0.5]

Fish [0.05] [0.5]

Chronic Birds [1] [1]

Mammals [1] [1]

Fish [1] [1]

Justification for Use:

Specific Best 

Management Practices 

(BMPs):

References:
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

G-44 Appendix G. Integrated Pest Management Program

Table CP.1 Pesticide Name

Trade Namea

Treatm

ent 

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/seas

on or 

gal/acre/seaso

n)

Minimum 

Time 

Between 

Application

s (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.
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix G. Integrated Pest Management Program G-45

G.8 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. Macon, MO.

ATSDR (Agency for Toxic Substances and Disease Registry) U.S. Department of Health and Human 

Services. 2004. Guidance manual for the assessment of joint toxic action of chemical mixtures. U.S.

Department of Health and Human Services, Public Health Service, ATSDR, Division of Toxicology. 62 

pp. (+ appendices).

Baehr, C.H. and C. Habig. 2000. Statistical evaluation of the UTAB database for use in terrestrial 

nontarget organism risk assessment. Presentation at the American Society for Testing and Materials 

(ASTM) Tenth Symposium on Environmental Toxicology and Risk Assessment, April 2000, Toronto, 

Canada.

Baker, J. and G. Miller. 1999. Understanding and reducing pesticide losses. Extension Publication PM 

1495. Iowa State University Extension. Ames, IA. 6 pp.

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, HI. 15 pp.

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, and S. Gerould. 1994. Estimates of soil ingestion by wildlife. Journal of 

Wildlife Management 58:375-382.

BLM (Bureau of Land Management). 2007. Vegetation treatments using herbicides on Bureau of Land 

Management Lands in 17 western states Programmatic EIS (PEIS). Bureau of Land Management. 

Washington, D.C. 539 pp.

Brooks, M.L., C.M. D’Antonio, D.M. Richardson, J.B. Grace, J.E. Keeley, J.M. DiTomaso, R.J. Hobbs, 

M. Pellant, and D. Pyke. 2004. Effects of invasive alien plants on fire regimes. BioScience 54:77-88.

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 pp.

Calabrese, E.J. and L.A. Baldwin. 1993. Performing ecological risk assessments. Chelsea, MI: Lewis

Publishers.

Center, T.D., J.H. Frank, and F.A. Dray, Jr. 1997. Biological control. Pages 245-263 in: D. Simberloff, 

D.C. Schmitz, and T.C. Brown, eds. Strangers in paradise: impact and management of nonindigenous 

species in Florida. Washington, D.C.: Island Press.

Coombs, E.M., J.K. Clark, G.L. Piper, and A.F. Cofrancesco, Jr. 2004. Biological control of invasive 

plants in the United States. Corvallis, OR: Oregon State University Press. 

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.
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

G-46 Appendix G. Integrated Pest Management Program

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. Cave Creek, AZ: Eldon Publishing.

EXTOXNET. 1993. 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 pp.

Fletcher, J.S., J.E. Nellessen, and T.G. Pfleeger. 1994. Literature review and evaluation of the EPA foodchain (Kanaga) 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. Corvallis, OR. 4 pp.

Kerle, E.A., J.J. Jenkins, and P.A. Vogue. 1996. Understanding pesticide persistence and mobility for 

groundwater and surface water protection. EM 8561. Oregon State University Extension Service. 

Corvallis, OR. 8 pp.

Masters, R.A. and R.L. Sheley. 2001. Invited synthesis paper: principles and practices for managing 

rangeland invasive plants. Journal of Range Management 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, and 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.

Mullin, B.H., L.W. Anderson, J.M. DiTomaso, R.E. Eplee, and K.D. Getsinger. 2000. Invasive plant 

species. Council for Agricultural Science and Technology Issue Paper (13):1-18.

Oregon State University. 1996. EXTOXNET-Extension Toxicology Network, Pesticide Information 

Profiles. Oregon State University. Corvallis, OR.

Pfleeger, T.G., A. Fong, R. Hayes, H. Ratsch, and 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, IA, and Iowa Department of Agriculture 

and Land Stewardship, Des Moines, IA. 6 pp.
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix G. Integrated Pest Management Program G-47

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, WA. 12 pp.

SDTF 2003 (Spray Drift Task Force 2003). 2003. A summary of chemigation application studies. Spray 

Drift Task Force. Macon, MO.

Urban, D.J. and N.J. Cook. 1986. Ecological risk assessment. EPA 540/9-85-001. U.S. Environmental 

Protection Agency, Office of Pesticide Programs. Washington, D.C. 94 pp.

USEPA (U.S. Environmental Protection Agency). 1990. Laboratory test methods of exposure to 

microbial pest control agents by the respiratory route to nontarget avian species. EPA/600/3-90/070. 

Environmental Research Laboratory. Corvallis, OR. 82 pp.

USEPA. 1998b. A comparative analysis of ecological risks from pesticides and their uses: background, 

methodology and case study. Environmental Fate and Effects Division, Office of Pesticide Programs, 

U.S. Environmental Protection Agency. Washington, D.C. 105 pp. 

USEPA. 2004. Overview of the ecological risk assessment process in the Office of Pesticide Programs, 

U.S. Environmental Protection Agency: endangered and threatened species effects determinations. Office 

of Pesticide Programs. Washington, D.C. 101 pp.

USEPA. 2005a. Technical overview of ecological risk assessment risk characterization; approaches for 

evaluating exposure; granular, bait, and treated seed applications. Available at: 

http://www.epa.gov/oppefed1/ecorisk_ders/toera_analysis_exp.htm. 

USEPA. 2005b. User’s guide TREX v1.2.3. Available at: 

http://www.epa.gov/oppefed1/models/terrestrial/trex_usersguide.htm. 

USFS (U.S. Forest Service). 2005. Pacific Northwest Region invasive plant program preventing and 

managing invasive plants final environmental impact statement. U.S. Forest Service. Portland, OR. 359 

pp.

USGS (U.S. Geological Survey). 2000. Pesticides in stream sediment and aquatic biota—current 

understanding of distribution and major influences. USGS Fact Sheet 092-00. U.S. Geological Survey.

Sacramento, CA. 4 pp.

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, HI. 8 pp.
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

G-48 Appendix G. Integrated Pest Management Program
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix H. Statement of Compliance H-1

Appendix H. Statement of Compliance

STATEMENT OF COMPLIANCE

for Implementation of the

Rose Atoll National Wildlife Refuge, American Samoa

Comprehensive Conservation Plan

The following Executive orders and legislative acts have been reviewed as they apply to 

implementation of the Rose Atoll National Wildlife Refuge CCP. 

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 U.S. 

Territory coastal management programs.

Endangered Species Act of 1973. This Act provides for the conservation of threatened and 

endangered species of fish, wildlife, and plants by Federal action and by encouraging the 

establishment of state programs. It provides for the determination and listing of endangered 

and threatened species and the designation of critical habitats. The CCP implementation is 

expected to result in supporting listed species and their recovery. Section 7 requires refuge 

managers to perform consultation before initiating projects that affect or may affect 

endangered species. The Refuge will conduct consultation under Section 7 of the Endangered 

Species Act for any Refuge management program actions that have the potential to affect 

listed species.

Essential Fish Habitat provision of the Magnuson-Stevens Fishery Conservation and 

Management Act (16 U.S.C. 1855(b))) provisions (§305(b)). Essential fish habitat (EFH) is 

defined as “those waters and substrates necessary to fish for spawning, breeding, feeding, or 

growth to maturity” and has been designated for all Management Unit Species Groups in the 

Pacific Islands Region, including Rose Atoll, for federally managed marine species. For coral 

reefs, EFH includes the water column above the reefs and all bottom out to 328-foot depth. 

The Refuge will conduct consultation for any Refuge management program actions that have 

the potential to adversely affect EFH. 

Executive Order 12372. Intergovernmental Review. Coordination and consultation with 

affected Tribal, local and State/Territorial governments, other Federal agencies, and the 

landowners has been completed through personal contact by the Refuge/Monument Manager.

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. 

Executive Order 13186. Responsibilities of Federal Agencies to Protect Migratory 

Birds. The CCP is consistent with Executive Order 13186 because the CCP and NEPA 

Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix I. Common Acronyms and Abbreviations I-1

Appendix I. Common Acronyms and Abbreviations

Administration Act National Wildlife Refuge System Administration Act of 1966 (16 U.S.C. 

668dd-668ee)

AHPA Archaeological and Historic Preservation Act

AM Adaptive Management

ASCC American Samoa Community College

ASG American Samoa Government

ASDOC American Samoa Department of Commerce

ASHPO American Samoa Historic Preservation Office

ATSDR Agency for Toxic Substances and Disease Registry

AUF Appropriate Use Findings

BIDEH Biological Integrity, Diversity, and Environmental Health

BLM Bureau of Land Management

BMP Best Management Practice

CCA Crustose coralline algae

CCP Comprehensive Conservation Plan

CD Compatibility Determination

CEQ White House Council on Environmental Quality

CFR Code of Federal Regulations

CITES Convention on International Trade in Endangered Species

CRED Coral Reef Ecosystem Division

CO2 Carbon Dioxide

DCCP/EA Draft Comprehensive Conservation Plan and Environmental Assessment

DM Departmental Manual

DMWR American Samoa Department of Marine and Wildlife Resources

DO U.S. Fish and Wildlife Service Director’s Order

DOI Department of the Interior

EA Environmental Assessment

EAR Ecological Acoustic Recorder

EE Environmental Education

EFH Essential Fish Habitat

ENSO El Niño Southern Oscillation

EO Executive Order

EPA U.S. Environmental Protection Agency

ES Ecological Services

ESA Endangered Species Act of 1973

FIFRA Federal Insecticide, Fungicide, and Rodenticide Act

FONSI Finding of No Significant Impact

Ft Feet (Foot)

FUDS Formerly Used Defense Sites

FW U.S. Fish and Wildlife Service Manual

FY Fiscal Year

GDP Gross Domestic Product

GHG Greenhouse Gases

HPINWRC Hawaiian and Pacific Islands National Wildlife Refuge Complex

I&M Inventory and Monitoring

IGC Inter-governmental Committee
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

I-2 Appendix I. Common Acronyms and Abbreviations

Improvement Act National Wildlife Refuge System Improvement Act of 1997

In Inch(es)

IPCC Intergovernmental Panel on Climate Change

IPM Integrated Pest Management

ISST Invasive Species Strike Team

IUCN International Union for Conservation of Nature

LCC Landscape Conservation Cooperative

LE Law Enforcement 

LEIS Legislative Environmental Impact Statement

MBCA Migratory Bird Conservation Act

MBTA Migratory Bird Treaty Act of 1918

Mi Mile(s)

MLLW Mean Lower Low Water

MMPA Marine Mammal Protection Act

MNMP NOAA’s Marine National Monument Program 

Monument Rose Atoll Marine National Monument

MOU Memorandum of Understanding

MPA Marine Protected Area

MSFCMA Magnuson-Stevens Fishery Conservation and Management Act 

NEPA National Environmental Policy Act

NGO Non-governmental organization

NHPA National Historic Preservation Act

NMI Nautical Miles

NMFS National Marine Fisheries Service

NMSAS National Marine Sanctuary of American Samoa 

NOAA National Oceanic and Atmospheric Administration

NOI Notice of Intent

NPS National Park Service

NRDA Natural Resource Damage Assessment

NRHP National Register of Historic Places

NWPS National Wilderness Preservation System

NWR National Wildlife Refuge

NWRC National Wildlife Refuge Complex

NWRS or

Refuge System National Wildlife Refuge System

ONMS Office of National Marine Sanctuaries

OSA Office of Samoan Affairs

PICCC Pacific Islands Climate Change Cooperative

PIFSC Pacific Islands Fisheries Science Center

PUP Pesticide Use Proposal

RAMP Reef Assessment Monitoring Program

RAPP Refuge Annual Performance Plan

REA Rapid Ecological Assessment

Refuge or RANWR Rose Atoll NWR

RHPO Regional Historic Preservation Officer

RM National Wildlife Refuge System Manual

RO Regional Office

ROC Resources of Concern

SDMP Step-down Management Plan
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix I. Common Acronyms and Abbreviations I-3

SLR Sea Level Rise

SSI Samoan Studies Institute

SUP Special Use Permit

T&E Threatened and Endangered

TBD To Be Determined

TL Total Length 

USC United States Code

USCG U.S. Coast Guard 

USFWS, FWS, 

the Service U.S. Fish and Wildlife Service

USGS U. S. Geological Survey

USPI U.S. Pacific Islands

WSA Wilderness Study Area
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan 

I-4 Appendix I. Common Acronyms and Abbreviations
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix J. Summary of Public Involvement J-1

Appendix J. Summary of Public Involvement

J.1 Summary of Public Involvement

The initial CCP planning process for the Refuge began in 2005. However, due to staff turnover and 

change in management, efforts did not truly get underway again until 2009. Public scoping began in 

the fall of 2009 with a notice in the Federal Register (November 9, 2009) and a total of three public 

meetings held in November 2009 at Manu’a Islands and on the Island of Tutuila. In all, over 60 

people participated in these meetings. Public input was also solicited through distribution of planning 

updates to our mailing list. Additionally, meetings with American Samoa and Federal agencies and 

elected officials, villages and chiefs, community groups, non-profit organizations, and others were 

also held. The comments and suggestions made through this process helped further develop and 

refine the management alternatives for the CCP, including the preferred alternative. It also helped to 

identify the top priority species, groups, and communities for the Refuge. The following is a brief 

summary of public involvement:

 2005 – CCP process briefing to DMWR;

 November 9, 2009 – Federal Register Notice (Vol. 74, No. 215) announcing a Notice of 

Intent to prepare the Draft CCP/EA and public open house meetings;

 November 2009 – Planning Update 1 announcing the official start of public scoping with 

public open house meetings and previewing preliminary issues and goals for CCP 

consideration; 

 November 2009 – Public scoping meetings on Ofu Island (November 14), Ta’u Island 

(November 16), and on the Island of Tutuila (November 19);

 2010–2011 – Refuge staff held specific meetings to provide updates and discuss management 

considerations with partners and interested parties (e.g., DMWR, Office of Samoan Affairs, 

etc.);

 March–April 2011– Formal letters inviting IGC members to participate sent (though 

briefings had been provided to individual members since 2005 even before the IGC had been 

formed); 

 May 2011 – Planning Update 2 summarizing public scoping comments and identifying issues 

outside the scope of the CCP;

 March 2012 – IGC review of draft Chapter 2 (Management Actions and Alternatives);

 June 2012 – IGC review of Draft Rose Atoll NWR CCP/EA;

 Fall 2012 – Release of Draft Rose Atoll NWR CCP/EA for an extended 50-day comment 

period (October 9-November 27, 2012) along with Planning Update 3 to the public and 

partners, which included public open houses in Tuituila and the Manu’a islands and 

community meetings and targeted meetings with interested groups/individuals.

Distribution and notification of the opportunities above was accomplished using multiple methods 

including news releases, a mail/email list of over 200 people (from scoping to Draft CCP/EA) which 

included interested individuals, local conservation and interest groups, research organizations, and 

Territorial and Federal government agencies and elected officials; community events/meetings; and 

CCP-specific website (http://www.fws.gov/roseatoll/planning.html).

The Draft CCP/EA and Final CCP reflect this extensive public involvement in all chapters as issues 

identified, related goals/objectives/strategies and alternatives drafted, and final management direction
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

J-2 Appendix J. Summary of Public Involvement

were shaped by the feedback received during public involvement. The following table summarizes 

the comments heard during public scoping and identifies where and/or how it was addressed in the 

Draft CCP/EA and Final CCP.

For all comments related to the Monument areas outside of the Refuge, the CCP only addresses the 

Refuge so these non-Refuge areas will be addressed through a later Monument planning process if 

necessary. The NOAA NMFS has management responsibility for fisheries outside of the Refuge 

area, in consultation with DOI.

Issue Where/How Addressed in Draft 

CCP/EA

Protection and Management

How will the unique status of the coral reef fish and invertebrates at 

Rose Atoll both inside and outside the lagoon be considered? The atoll 

is one of the smallest in the world and only the upper 300 feet of the 

pinnacle forming Rose Atoll receives enough light to support 

significant coral growth. This small extent of habitat does not provide 

the resilience afforded to larger coral reefs that have more habitat 

complexity and larger fish populations to maintain the natural 

replenishment populations. Small areas like Rose Atoll are easily 

fished out. Rose Atoll should be viewed in its regional context – it is 

part of a remote group of Pacific Islands (the Samoan Archipelago) 

that form an integrated biological unit that is critical to the continuity 

of local coral reef ecosystems.

Proposed management actions can be 

found in Chapter 2 addressing protection 

of the unique coral reef fish and 

invertebrates at Rose Atoll; recognition of 

Rose’s small area and fishing concerns 

can be found in Chapter 4.

Create an effective management strategy that multiple government 

agencies with competing mandates and priorities will adhere to, in 

order to provide effective oversight and protection of the area.

Proposed management actions 

highlighting partnering can be found in 

Chapter 2.

Include a comprehensive threats section and concrete steps to address 

these threats. The threats to consider should include, but are not limited 

to, illegal foreign/domestic fishing; potential ship groundings; by‐catch 

of monument seabirds, sea turtles, and migratory fishes in waters 

adjacent to monument boundaries; invasive species; altered and 

disrupted landscapes and habitats; land and marine debris; and global 

warming impacts.

Threats to habitats and species can be 

found in Chapter 4; proposed 

management actions to address threats 

can be found in Chapter 2.

Research and Monitoring

Encourage and support research to document the condition of the 

ecosystems in the monument, track resource trends, and identify the 

connections between the island and its surrounding pelagic waters and 

seafloor.

Proposed management actions 

highlighting such research can be found 

in Chapter 2 under Goal 6.

How will the CCP consider and analyze the impacts of climate change? 

The CCP should outline a plan to inventory and monitor climate 

change-related variables and trends. The CCP should include climate 

change information in environmental education programs. The CCP 

must address non-climate stressors (climate change will add to existing 

stressors such as invasive species, habitat fragmentation, 

overharvesting, so these issues must also be addressed). The CCP 

vision should acknowledge important role that climate change will play 

in future conditions of Rose Atoll NWR. Refuge should promote 

ecosystem resiliency.

Climate change is analyzed as part of 

affected environment Chapter 3, 

biological environment Chapter 4, 

environmental consequences Chapter 6 as 

well as proposed management actions in 

Chapter 2. 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix J. Summary of Public Involvement J-3

Issue Where/How Addressed in Draft 

CCP/EA

Enforcement

How will the enforcement of the atoll be conducted [the commitment 

was made that the need for a boat for enforcement will be identified in 

the CCP] and will Manu’a residents be considered to conduct 

enforcement (e.g., as first responders)?

Enforcement considering Manu’a 

residents is identified in Chapter 2. 

Include a realistic plan for effective surveillance and enforcement of 

the monument.

Surveillance and enforcement of the 

Refuge (which is part of the Monument) 

is identified in Chapter 2. 

Visitor Services and Education

What educational opportunities can be provided? Education can be 

used to gain support and participation of youth in Manu’a in the 

conservation of Rose Atoll. There is a need to send over educational 

materials and resources to help enhance community awareness and 

understanding. A science education program for local students to learn 

more about the marine environment and resources would help 

encourage Manu’a students to pursue interests in science and to 

become scientists (marine biologists) in the future. Fish and habitats of 

Rose Atoll should be in DVDs and posters. Hold community 

workshops to educate about the resources [at the meeting, the 

commitment was made that education programs and opportunities 

would be developed and included in the plan].

Educational opportunities are identified in 

Chapter 2. 

What opportunities for tourism can be developed and will there be 

opportunities for touring the atoll?

Tourism does not meet the Refuge 

purpose (outlined in Chapter 1).

Therefore, tourism was not considered 

(see Chapter 2).

Cultural

The name of Rose Atoll could be changed back to the original Samoan 

name to protect the culture and heritage.

This is identified as a strategy under Goal 

8 in Chapter 2. 

Discussion of subsistence, sustenance, and recreational fishing 

opportunities should be discussed.

For areas within the Refuge, this issue is 

addressed in Chapter 2, with biological 

justifications outlined in Chapter 4. The 

conclusion was that fishing was 

considered, but not developed further in 

the CCP. For areas outside the Refuge 

(and therefore outside the scope of the 

CCP), a separate process through NMFS 

is underway.

Local participation should be included in management of the atoll (e.g., 

jobs for ASCC and high school students).

Through cultural practices, enforcement, 

environmental education, outreach, and 

research, local participation was 

integrated into proposed management 

actions found in Chapter 2.
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

J-4 Appendix J. Summary of Public Involvement

Issues Outside the Scope of the CCP

 How can the boundary of the Rose Atoll National Monument be changed? Please consider our request to reduce 

the area closure around Rose Atoll National Monument to 12 miles.

 Will the Manu’a people, especially those in Ta’u Island, be allowed to fish at the atoll? Can the Manu’a people 

be allowed to fish within the 50-nmi zone? There were a number of individuals that expressed concern that the 

waters of Manu’a should be kept for the people of Manu’a to carry on their tradition of fishing and allow them 

to develop their fisheries.

 Will the establishment of the Monument provide jobs for the Manu’a people? NOAA should establish an office 

in the Manu’a Islands to assist the community in enforcement and management of the Monument.

Major comments received during the Draft CCP/EA public comment period and how they were 

addressed in the Final CCP are reflected below. However, comments concerning technical/minor 

edits are not reflected, but were incorporated where relevant into the Final CCP. Authors of 

comments are included in parentheses.

Issue Where/How Addressed in Final CCP

Explain the relationship between seabirds and pelagic fish 

(NOAA)

Clarifying text was added to the beginning of 

section 4.5 in Chapter 4. 

Desire for more than 30 days to comment (ASDOC) The public comment period was extended 

through November 27, 2012 (from initial close 

date of November 9, 2012), for a total time 

period of 50 days.

Clarification needed on how the Service plans to build on comanagement and coordination for resources, enforcement, and 

outreach (ASDOC and Marine Conservation Initiative)

This issue was addressed in Chapter 1, 

section1.9.3, last paragraph. The Monument is 

managed by the Service in consultation with our 

partners and Monument management is outside 

the scope of this document. The Service has sole 

management responsibility for the Refuge, but 

we work very closely with DMWR and treat 

them as a cooperating agency. 

The following comments were submitted by the Marine 

Conservation Initiative:

1. Urge NOAA to advance fishing regulations outside 

refuge

2. Increase the penalty for fishing/trespass in the atoll 

($500 is too small)

3. Ensure monument/refuge boundaries are accurately 

portrayed on government/commercial nautical charts 

with outreach to vessel owners/captains

4. Better identify in goal 6 research related to linking land 

and sea. 

1. Agree. The final rule for fishery 

management measures within the 

Monument were established by NOAA in 

June 2013.

2. This penalty is not specific to the Refuge, 

but is the penalty set for all refuges for such 

violations.

3. Additional text was added to Chapter 2, 

section 2.3 under law enforcement. The 

Service is presently working with NOAA to 

ensure that all Pacific Island refuges are 

labeled as Monuments on nautical charts.

4. Two new research strategies were added in 

Objective 6.2 in Chapter 2.

Allow fishing at Rose Island once or twice a year under the 

National Park Rules (anonymous)

This issue was addressed in chapter 2 (section 

2.2) as to why fishing will not be allowed. NPS

regulations do not apply to Rose Atoll NWR.
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix J. Summary of Public Involvement J-5

In addition to the above, four public open houses were held involving over 40 participants (see 

summaries below). 

October 16, 2012, 2:00 p.m. Rose Atoll NWR CCP Public Open House

Sadie’s by the Sea, Pago Pago

Comments and responses were as follows:

 The Refuge cannot be there because of the Deed of Cession. A man pulled out a copy of the 

Fagatele Bay (National Marine Sanctuary of American Samoa) Federal Register and asked 

about 48 U.S.C. 1661. 

o We cannot answer technical legal questions. Additionally, it was pointed out that the 

Governor, the Fono (American Samoa Legislature), and the President have all signed 

papers confirming that Rose Atoll is indeed a NWR. 

 Had we met with the chiefs of Manu’a?

o Ray Tulafono (Director of DMWR) explained that we approached the Secretary of 

Samoan Affairs before the comment period opened and explained that our comment 

period would close on November 9 and that Service would be available for a meeting 

with the chiefs of Manu’a at any time. The Secretary of Samoan Affairs explained 

that several of the chiefs were candidates for governor, and that a meeting could not 

be planned until after November 9. 

 A goal relating to cultural issues is identified. Have we given the chiefs a chance to 

comment?

o The Refuge Manager (Frank Pendleton) explained again that we approached the 

Secretary of Samoan Affairs who did not want to have a meeting until after the 

election. The Service will meet with the chiefs when the Secretary sets up a meeting. 

While this will be after the comment period for the CCP the Service will still listen to 

their comments and consider them in the management of the Refuge. 

Note: The public meeting in Ta’ū was attended by 15 local chiefs. Additionally, following standard 

protocols to arrange a meeting with Manu’a chiefs, we contacted the OSA on several occasions. 

Initial contact with OSA was made in September by the Director of our cooperating agency, the 

DMWR. However, due to the gubernatorial election and transition of the OSA, the Refuge Manager 

was advised that no action would be taking place at this time. We plan to continue discussions with 

all parties interested in the management of the Refuge on a regular basis. The OSA will be reengaged and discussions with the Manu’a chiefs will be on going. It should also be noted that the 

goal relating to cultural issues was also developed in part from feedback from the Manu’a chiefs 

when the Refuge began its public scoping process in 2009.

October 18, 2012, 9:00 a.m., Rose Atoll NWR CCP Public Open House

Ofu Community Center

Participants asked a few questions about the natural history of Rose Atoll, but nothing about the 

CCP. 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

J-6 Appendix J. Summary of Public Involvement

October 22, 2012, 1:00 p.m., Rose Atoll NWR CCP Public Open House

Pita’s Fale

 Can we fish at Rose?

o No. The Refuge is closed to all entry, including for fishing, to protect the fish and 

wildlife in the Refuge. Additionally, NMFS is working on Fishing Regulations for 

the Monument and it is likely that fishing will be prohibited within 12 nmi of the 

Refuge. (Attendees were directed to NOAA NMFS handouts explaining fishing 

regulations).

 Can local people go on Service trips to Rose?

o Anyone wishing to enter the Refuge must obtain a Special Use Permit from the 

Refuge Manager. On rare occasions a local resident may be able to come on a trip 

with the Service, but we only go 3 times a year and most boats are full of researchers. 

 Can we eat the faisua (giant clams)?

o Nothing may be taken from the Refuge, including the faisua. 

 Can sailboats go to Rose?

o Sailboats wishing to enter the Refuge must have a Special Use Permit. 

 Is Rose part of American Samoa?

o Yes, Rose Atoll is part of American Samoa, and specifically part of Manu’a. It is 

managed under the Service’s jurisdiction, but is still owned by/part of American 

Samoa. 

In addition to the two open houses, a NPS employee accompanied the Refuge Manager Frank 

Pendleton around Ofu and Olosega to meet with various people. One was the daughter of the 

Pulenu’u (Mayor). She was acting in his place while the Pulenu’u was off island. He informed her 

about the meeting to be held on the 22nd and gave her a copy of the CCP. 

October 23, 2012, 2:00 p.m., Rose Atoll NWR CCP Public Open House 

Manu’a High School (Ta’ū) 

Many of the attendees were members of the Village Council and several of the attendees spoke in 

Samoan in formal style before the beginning of the presentation. 

 Rose Atoll is part of Manu’a, and was taken away without consultation. 

o Rose Atoll has not been taken away. It is still part of American Samoa and 

specifically part of Manu’a. Additionally, it is also a National Wildlife Refuge. The 

Refuge was created in 1973 by a Cooperative Agreement between the Service and 

Governor Haydon, which was approved of by the Fono (American Samoa 

Legislature) by a Concurrent Resolution. Both of these documents are in the Draft 

CCP/EA (attendees were shown where they could find this in the document). 

 The chiefs who actually live in Manu’a should be taken to Rose Atoll.
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix J. Summary of Public Involvement J-7

o It would not be possible to take all the Chiefs who actually live in Manu’a to Rose 

Atoll; on occasion a Manu’a Chief could be taken on a trip to Rose Atoll [Some 

already have been and Goal 7 is related to this]. 

 The Fono was not aware of 48 U.S.C. 61 and 62 when they prepared the Senate Concurrent 

Resolution approving the Cooperative Agreement that created the Refuge.

o The Refuge Manager Frank Pendleton cannot comment on what the Fono knew in 

1973. 

 The chiefs have filed a claim concerning the 50 nmi area and would like to see it shrunk 

back down to 12 nmi. 

o The President of the United States, the Governor of American Samoa, the Fono, 

and the Regional Director of the Service have all signed papers creating or 

legitimizing the Refuge. 

o NOAA NMFS is working on the fishing regulations for the Monument areas 

outside of the Refuge. The area that will likely be closed to all fishing is 12 nmi 

from the Refuge. Local, non-commercial fisherman will likely be allowed to fish in 

the Monument as long as they are more than 12 nmi from the Refuge. 

o A handout from NOAA NMFS was made available explaining the “No Fishing 

Zone”.

 Since Rose Island is in Manu’a it would be a good idea to put the Service office in Manu’a.

o An office in Manu’a would be nice, but there are many challenges to locating an 

office in Manu’a. Currently an office in Tutuila exists.

 We do not like the name Rose Island. It should be changed to a Samoan name, either 

Muliava or Nuu o Manu, or a combination of the two.

o A name change to a Samoan name is being considered. [Note Goal 7.]

 We would like to see some jobs created in Manu’a regarding the Refuge/Monument.

o The Service would also like to see this, but under present budget considerations any 

jobs that may develop are unlikely any time soon.

. 

 The Service should come to Manu’a more often.

o Yes, the Service should come to Manu’a more often. Now that we have a person 

stationed on Tutuila this is possible.

 Manu’a would like something out of this (e.g., jobs, environmental education, etc.).

o Refuge Manager Frank Pendleton gave a talk at Olosega Elementary School, and 

will be giving talks at Manu’a High School during this trip. [In the Final CCP, 

increased outreach as well as environmental education is proposed under Goal 7.]

 Manu’a kids should have the chance to be interns before other kids.

o We will consider it. A consideration would be if students are enrolled at American 

Samoa Community College in a Natural Resource program.

 Only Manu’a people should be able to fish in the Monument and they should also be able 

to fish the Refuge. 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

J-8 Appendix J. Summary of Public Involvement

o There is presently no fishing in the Refuge to protect the tiny lagoon which could 

easily be overfished. NOAA NMFS creates fishing regulations for the Monument. 

 It is important to meet with the Village Council here in Manu’a, and not only with the 

Chiefs and Pulenu’u that the OSA suggests. 

o The Service will strive to meet with the Village Council regularly.

 The Service should inform the Manu’a Representatives in the Fono about the CCP and 

anything else going on at Rose Atoll. 

o Upon the Refuge Manager’s return to Tutuila, he will try to meet with the Manu’a 

Representative in the Fono.
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix K. Cooperative Agreement and Presidential Proclamation K-1

Appendix K. Cooperative Agreement and Presidential 

Proclamations

This cooperative agreement was the basis for the establishment of Rose Atoll National Wildlife 

Refuge.
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

K-2 Appendix K. Cooperative Agreement and Presidential Proclamation
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix K. Cooperative Agreement and Presidential Proclamation K-3
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

K-4 Appendix K. Cooperative Agreement and Presidential Proclamation
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix K. Cooperative Agreement and Presidential Proclamation K-5
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

K-6 Appendix K. Cooperative Agreement and Presidential Proclamation

Federal Register Notice of Establishment (39 FR 13183)
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix K. Cooperative Agreement and Presidential Proclamation K-7

Presidential Proclamation 4347 establishing additional jurisdiction.
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

K-8 Appendix K. Cooperative Agreement and Presidential Proclamation
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix K. Cooperative Agreement and Presidential Proclamation K-9
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

K-10 Appendix K. Cooperative Agreement and Presidential Proclamation
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix K. Cooperative Agreement and Presidential Proclamation K-11
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

K-12 Appendix K. Cooperative Agreement and Presidential Proclamation
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix K. Cooperative Agreement and Presidential Proclamation K-13
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

K-14 Appendix K. Cooperative Agreement and Presidential Proclamation
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix L. Best Management Practices for Visitors to Rose Atoll L-1

Appendix L. 

Best Management Practices for Visitors to Rose Atoll NWR

Best Management Practices (BMPs) for Rose Atoll NWR are in place to minimize the effects of 

visitors to the Refuge. They are designed to prevent the introduction of nonnative species and to 

minimize disturbance of wildlife. There are strict requirements for vessels to have their hulls cleaned 

and to be treated for insects, mice, and rats, and quarantines for all gear that will be brought to the 

Refuge to prevent the introduction of plants and insects. Additionally, the use of lights is minimized 

to prevent disturbing seabirds and sea turtles. 

Quarantine Requirements: 

Introduced species are a big threat to Rose Atoll. The introductions of rats (Rattus exulans), the 

scale insect (Pulvinaria urbicola), and multiple species of ants have caused severe damage to the 

native communities of Rose Atoll. Rats were successfully eradicated from Rose Atoll in 1992 at 

considerable expense. The scale insect has contributed to the drastic decline of the pu’a vai forest 

(Pisonia grandis) on Rose Island, and is tended by introduced ants. Other Pacific remote refuges 

have had various plant, insect, rodent, and other pest species introduced. In some cases, these 

pests have caused major changes to natural communities, greatly reduced the value of islands as 

seabird nesting sites, and have cost millions of dollars to control. 

While the policies and practices outlined below may seem severe, they are required to prevent 

other introductions and must be followed. The Service has found them to be effective at 

preventing new introductions of invasive species on National Wildlife Refuges throughout the 

tropical Pacific. Remember: just one gravid female or one seed can be enough to introduce an 

unwanted species. “An ounce of prevention can be worth millions of dollars in eradication.” 

Suitable Plastic Packing Container:

Packing containers must be constructed of smooth, durable plastic which can be easily cleaned 

and will not harbor seeds or insects. Corrugated plastic boxes such as mail totes are not 

acceptable. Packing containers may be re-used for multiple trips to Rose, but must be thoroughly 

cleaned before each trip. 

Quarantine Inspections: 

All personal gear, supplies, equipment, machinery, and vessels will be inspected for quarantine 

compliance by Service staff in Tutuila prior to departure for Rose Atoll.

Prohibited Items: 

• Fresh fruits and vegetables, rooted plants, cuttings, flowers, and seeds;

• Soil, sand, and gravel;

• Animals; and

• Cardboard (paper and plastic cardboard harbors seeds and insects).
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

L-2 Appendix L. Best Management Practices for Visitors to Rose Atoll

Regulated Items: 

Food items have the potential to carry alien pests and are therefore selected, packed, and shipped 

with great care. Fresh fruits and vegetables are not allowed on Rose Island. Wood products often 

harbor seeds and insects. Therefore, only treated wood that has been painted or varnished may be 

taken to Rose. Wood items must be approved by the Refuge Manager.

Packing Procedures:

Ensure that the environment selected for packing has been well cleaned and free of seeds and 

insects. Keep packing containers closed as much as possible throughout the packing process so 

insects cannot crawl in before the containers have been securely closed. Quarantine procedures 

should be performed as close to the transportation date as possible to minimize the chances for 

pests to infect them.

Clothing and Soft Gear:

All persons going ashore on Rose Island or Sand Island must have NEW or ROSE-DEDICATED 

clothing and soft gear (including all footwear). This rule applies to anyone stepping on to dry 

land past the intertidal zone.

All clothing and soft gear must be frozen for 48 hours (including both new and Rose-dedicated).

Aquatic Gear:

All aquatic gear such as nets and traps must be Rose-dedicated and must not be used at other 

research sites.

Dive gear must be visually inspected for any algae or other marine life, soaked in fresh water for 

24 hours, and then allowed to dry. Visual inspections should include inside pockets. 

Alternatively, dive gear can be soaked in a bleach solution (1 cup bleach/5 gallon water) for a 

minimum of 5 minutes, and then rinsed in fresh water and allowed to dry. 

Sensitive Equipment:

All sensitive gear (optical equipment, computers, satellite phones, and other electronic 

equipment) need not be frozen or fumigated, but must be thoroughly inspected and cleaned.

Straps for cameras and binoculars or other gear must be visually inspected for seeds and insects 

and frozen for 48 hours. 

Non-Sensitive Equipment and Construction Materials:

All non-sensitive equipment, machinery and construction materials that are water resistant must 

be steam-cleaned or pressure-washed to ensure the removal of all dirt, insects, and seeds from 

external surfaces. 

All non-water resistant items must be tented and fumigated to kill unwanted pests, or frozen for 

48 hours. 

Small boats must be thoroughly washed down, fumigated, and hulls carefully cleaned before 

transport to Rose Atoll NWR. 
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix L. Best Management Practices for Visitors to Rose Atoll L-3

Commercial Ships and Private Sailing and Motor Vessel Quarantine:

Ship owners or captains will ensure that ships are free of rats, insects, seeds, and all other alien 

species prior to departing for Rose Atoll. They will ensure that rodent bait stations containing 

rodenticide and traps have been placed on the ship and barge decks and holds throughout their 

voyage to Rose as well as throughout the duration of the stay within the Refuge.

Ship owners or captains will notify the Refuge Manager at least 5 working days prior to a vessel 

departing for Rose Atoll in order to arrange a quarantine inspection. The inspection will be 

scheduled as close to the departure date as possible.

Ship owners or captains will ensure that all ships entering Rose Atoll have had their hulls cleaned 

of fouling marine organisms. The ships must depart for Rose Atoll within 14 days of having had 

the hulls cleaned. All ship hulls must be re-cleaned should the vessel return to a port for greater 

than 14 days before returning to Rose Atoll. The Refuge Manager must be notified prior to 

cleaning the hull, in order to observe the cleaning and inspect the hull. 

No discharge of ballast water, grey water, sewage (blackwater), or waste of any kind will be 

allowed by any vessel within 12 nautical miles of Rose Atoll. 

Minimizing Disturbance of Wildlife

Seabirds:

Most seabirds exhibit insular tameness, which is behavior characterized by a lack of the wariness 

you might observe in birds living in areas with terrestrial predators. Because of this, it sometimes 

appears by their actions as if humans pose no problems for them. In fact there are a number of 

potentially serious consequences every time a seabird colony is entered, even by experienced 

researchers.

Mechanical – At most seabird colonies in the central Pacific you will see birds nesting on three 

different levels; under the ground, on the surface, and in the shrubs and trees. At many times of 

the year it is difficult to walk in some parts of the colony without stepping on eggs or caving in 

the burrows of the petrels and shearwaters. Chicks of several of the tern species hide in 

vegetation so you should be careful about setting your foot where you cannot see the surface of 

the ground. Ground-nesting gogosina (grey-backed terns) and gogo (brown noddies) are often 

affected by your activities because they are very timid and nest in open areas that may be travel 

pathways. If you have occasion to have to walk in burrow areas you must be prepared to rescue a 

shearwater or petrel by digging if you accidentally cave in its home. Special care should be taken 

never to leave string or line anywhere in the colony. Seabirds have an uncanny ability to find it 

and get tangled in any material of this kind.

Thermal – Eggs and small chicks of all the species live a precarious life on the edge of thermal 

disaster. The attendance pattern of adults reflects this with eggs and tiny chicks rarely left 

unattended. Great care and attention must be given to avoid keeping a bird off its egg or chick for 

more than a few minutes. Keep this in mind if you must spend more than 3 or 4 minutes in any 

area. This is an issue when it is hot as well as when it is cool and wet. When first approaching a 

site look for any nests or adults flushed from an inconspicuous nest and plan your work to 

minimize the time parents are kept away from eggs or chicks.
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

L-4 Appendix L. Best Management Practices for Visitors to Rose Atoll

Biological – In some colonies, one species may learn to take advantage of human disturbance to 

prey upon others. Atafa (frigatebirds) will take chicks and steal nest material from booby nests 

and other frigatebird nests when the owners of the nest are frightened off by human disturbance. 

Unattended eggs of ground-nesting species are often eaten by shorebirds such as ruddy 

turnstones. 

When first arriving at the landing area, a careful reconnaissance of existing ground nests in the 

area of the proposed camp should be made by a person familiar with the behavior of brown 

noddies and brown boobies. Campsite locations of tents and the cooking area should be chosen 

to avoid causing any modification of the behavior of incubating or brooding seabirds. Proximity 

of camp activity to active ground nests will result in a nest failure if the adult bird is too 

frightened to return and protect the egg or chick from temperature extremes or to feed the chick. 

It is also important to be careful with lights when camping. Lights should be kept to a minimum, 

and should not be pointed into nesting colonies or into trees where birds are nesting. Bright lights 

can temporarily blind and disorient birds, and cause them to flush. This can cause the bird to hurt 

itself by falling from the nest or flying into trees, or cause eggs to be broken. 

Turtles:

Hawksbill turtles occur in the Refuge, but have not been seen nesting. I’a sa (green turtles) mate 

and nest on Rose Atoll August–February. Turtles nesting on Rose Island have been known to dig 

as many as five nest pits before depositing their eggs. To avoid scaring nesting turtles away, 

lights in camp should be minimized, and red lights should be used August–February. 

Land Crabs:

 The shells of marine mollusks are abundant on the beaches of Rose Atoll but almost every one of

 them is already being used by the land crabs resident there. Even the tiniest shells often have 

young crabs in them so shell collecting is not permitted while visiting Rose.
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix M. CCP Team Members M-1

Appendix M. CCP Team Members

M.1 CCP Team Members

The CCP was developed and prepared primarily by a core team made up of refuge staff (both local 

and at the Honolulu offices). The core team sought expertise and review from other professionals 

from several different agencies and organizations. The List of Preparers below includes core team 

members as well as other persons responsible for writing specific portions of the plan. Many others 

provided assistance in developing and reviewing the CCP and associated products and in providing 

advice through the planning process. These people are captured in the List of Reviewers and 

Advisors. 

Table M-1. List of Preparers (in alphabetical order)

Name and Title CCP Contributions 

Liz Cruz, Geographer/GIS Specialist, RO 

replaced,

David Hoy, Geographer/GIS Specialist, RO

GIS data gathering and analysis (e.g., habitats and 

vegetation, infrastructure, alternatives development); 

development of maps for public involvement and 

documents

Beth Flint, Biologist, Pacific Reefs NWRC Writer of biological affected environment; reviewer; 

lead on biological goals/objectives/strategies, 

biological component on affected environment and 

related environmental consequences; biological 

resources of concern, taxa lists, and habitats, 

integrated pest management; research/analysis; 

coordinated with biological and natural resource 

management partners; reviewed AUFs/CDs

Jean Kenyon, Biologist, Inventory and 

Monitoring Program, RO

Writer of biological affected environment; reviewer; 

lead on marine biological goals/objectives/ strategies, 

biological component on affected environment and 

related environmental consequences; biological 

resources of concern, taxa lists, and habitats; 

research/analysis; reviewed AUFs/CDs

Jiny Kim, Biologist, Pacific Reefs NWRC Writer of biological affected environment; reviewer;

biological goals/objectives/strategies; biological 

resources of concern, taxa lists, and habitats; 

research/analysis

Jim Maragos, Biologist, Pacific Reefs NWRC 

(retired)

Writer of biological affected environment; taxa lists 

and habitats
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

M-2 Appendix M. CCP Team Members

Name and Title CCP Contributions 

Frank Pendleton, Refuge/Monument Manager, 

Rose Atoll NWR and Marine National 

Monument

Team leader; decision-maker and document quality 

reviewer; writer of affected environment, public 

involvement and communications (including 

coordination of Federal, Territorial, partner, and 

community organizations); compatibility 

determinations and implementation; overall guidance 

for CCP development and coordination with staff

Khemarith So, Planner, RO replaced,

Christine Ogura, Natural Resource Planner, 

HPINWRC replaced,

Bill Perry, Natural Resource Planner, HPINWRC 

CCP lead planner responsible for RO and Honolulu 

office coordination and process and policy guidance 

for CCP development; CCP schedule manager; 

facilitator of team, partner, and public 

meetings/workshops; document and related product 

management (including planning record); writer of 

affected environment and environmental 

consequences and planning updates; public 

involvement and communications

Susan White, Project Leader, Pacific Reefs 

NWRC 

Decision-maker and document quality reviewer; 

overall guidance for CCP and CDs development and 

coordination with staff

Table M-2. List of Reviewers and Advisors (in alphabetical order)

Name and Title CCP Contributions 

Midori Akamine, Director, Marine National 

Monument Program in the Pacific Islands Region

Review of Chapter 2 and entire document

Laura Beauregard, Acting Deputy Refuge 

Supervisor, HPINWRC replaced

Don Palawski, Deputy Project Leader, 

HPINWRC (retired)

Assist with regional office coordination; reviewer of 

document and related products; guidance on overall 

process and components; technical review and 

editing 

Gene Brighouse, Superintendent, National 

Marine Sanctuary of American Samoa 

Review of Chapter 2 and entire document

Samantha Brooke, Fishery Policy Analyst,

NOAA Fisheries Pacific Islands Regional Office,

Marine National Monument Program

Review of Chapter 2 and entire document

Tim Clark, Marine Ecologist, National Park of 

American Samoa

Review of Chapter 2 and entire document

Peter Craig, Chief of Natural Resources, National 

Park of American Samoa (retired)

Review of Chapter 2 and entire document

Sean Eagan, Chief of Resources Management, 

National Park of American Samoa

Review of Chapter 2 and entire document

Joe Engler, Assistant Regional Biologist, RO Review of biological goals/objectives/strategies
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

Appendix M. CCP Team Members M-3

Name and Title CCP Contributions 

Bridgette Flanders-Wanner, Assistant Regional 

Refuge Biologist and Regional IPM Coordinator, 

RO

Lead reviewer of biological 

goals/objectives/strategies; IPM

Holly Freifeld, Biologist, Division of Migratory 

Birds and Habitat Programs, RO

Reviewer of biological goals/objectives/strategies

Kevin Grant, Deputy Superintendent, National 

Marine Sanctuary of American Samoa

Review of Chapter 2 and entire document

Richard Hall, Fishery Policy Analyst, NOAA, 

Pacific Islands Region, National Marine 

Fisheries Service

Review of entire document, coordinated comments 

from NOAA’s PIRO’s Protected Resources, Habitat 

Conservation, and Sustainable Fisheries Divisions, 

and the National Marine Monument Program

Ben Harrison, Deputy Regional Chief of 

Refuges, RO

CCP Advisor, reviewer of policy, AUF, CDs, 

environmental consequences

Charles Houghten, Division Chief Planning, 

Visitor Services, Transportation, RO

CCP Advisor for planning policy and guidance; 

reviewer (including wilderness); coordination with 

other divisions and the Washington D.C. office

Kay Kier-Haggenjos, Writer/Editor, RO Technical edit review; review and processing of 

document and related products (e.g., planning 

updates) 

Nicole McCarthy, Writer/Editor, RO Assist with public comment period coordination and 

processing of Federal Register notices

Scott McCarthy, Chief, Conservation Planning, 

RO

CCP Advisor for planning policy and guidance; 

planning workload priorities; coordination with other 

divisions

Kevin O’Hara, Planner Reviewed Chapter 6 effects analysis

Sandra Hall, External Affairs, HPINWRC Layout and reviewer of planning updates; Website 

management; CCP cover editing

Domingo Ochavillo, DMWR Fisheries Biologist Review of Chapter 2 and entire document

Charles Parrott, Realty Specialist, RO Realty analysis, review of related sections in 

document, assisted with verifying map accuracy 

Lelei Peau, Deputy Director, American Samoa 

Department of Commerce

Review of Chapter 2 and entire document

Mike Reynolds, Superintendent, National Park of 

American Samoa

Review of Chapter 2 and entire document

Patrick Stark, Visitor Services and 

Communication, RO

Document and related products (e.g., planning 

update) print management; CCP cover design

Barry Stieglitz, Refuge Supervisor, HPINWRC Decision-maker and document quality reviewer 

(including CDs)
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

M-4 Appendix M. CCP Team Members

Name and Title CCP Contributions 

Robyn Thorson, Regional Director, RO Final decision-maker on DCCP/EA and Final CCP;

Federal Register Notice approvals

Ray Tulafono, Director, DMWR Review of Chapter 2 and entire document; 

coordinated and assisted with public meetings and 

document translations

Jared Underwood, Zone Inventory and 

Monitoring Biologist, HPINWRC

Reviewer of biological inventory and monitoring 

strategies

Robin West, Regional Chief of Refuges, RO Major decisions on CCP direction, DCCP/EA and 

Final CCP and CDs; Federal Register Notice 

approvals

Lee Ann Woodward, Resource Contaminants 

Specialist, Pacific Reefs NWRC

Contaminants section in affected environments
Rose Atoll National Wildlife Refuge Comprehensive Conservation Plan

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U.S. Department of the Interior

U.S. Fish & Wildlife Service

Rose Atoll National Wildlife Refuge

c/o National Park Service

Pago Pago, AS 96799

May 2014

Front Cover Photos

Main: An array of seabirds find refuge

at Rose Atoll.

USFWS

Inset: Pu’a vai tree

JE Maragos/USFWS

Tava’e’ula chick

Greg Sanders/USFWS

Faisua

JE Maragos/USFWS

Rose Atoll’s beauty is embellished by 

the vibrant pink hue of its reefs. 

Its primary element of 

construction is the 

pink calcareous 

coralline alga 

Porolithon.

USFWS