A-1 

8.0 Appendices 

Appendix A: Resource Equivalency Analysis 

Background

There are two basic approaches to measuring the compensation for natural resources 

injuries. One is to focus on the demand side, the “consumer valuation approach”; the 

other is to focus on the supply side, the “replacement cost” approach. In the former, we 

seek to measure the monetary value that the public puts on the natural resources (i.e., how 

much the public demands the services of natural resources); in the latter, we seek to 

measure how much it costs to replace the natural resource services that the public loses as 

a result of the injury (i.e., how much it costs to supply natural resource services). See the 

Glossary for complete definitions of some of the terms used here. 

Figure 1: Consumer Valuation versus Replacement Cost Approaches for Natural 

Resource Damage Calculation 

Figure 1 illustrates the difference between these two approaches. In both graphs, the 

supply of natural resources shifts from S0 to S1 as a result of an incident (e.g., oil spill, 

sediment discharge into a stream, illegal removal of vegetation). The shaded area in the 

top graph illustrates the dollar value of the resource loss as measured by the monetary 

payment that would make the public indifferent to the incident. For example, if each 

individual in a 30 million person society would need a $.05 payment (on average) to 

make them indifferent to the resource loss, the shaded area in the top graph would equal 

$1.5 million. Because the difficulty in observing market prices that reveal the level of 
 A-2 

cash payment that would compensate individuals for resource losses, the quantitative 

characteristics of the demand curve(s), and consequently the size of the shaded area in the 

upper graph, are difficult to measure. Contingent Valuation (CV) and other types of 

analyses are designed to estimate this dollar value. These methodologies typically 

involve large surveys and can be costly. 

The lower graph illustrates a replacement cost approach. Beyond noting that the injured 

resource has value, the actual extent to which the public values it is not directly 

considered. Instead, the determination of adequate compensation depends on the level of 

natural resource provision (versus monetary payments) that compensates society for what 

it has lost as a result of the incident. The cost of providing this compensation becomes the 

estimate of damages. Resource Equivalency Analysis (REA) is the primary methodology 

for conducting this type of measurement in natural resource damage assessment. It is 

depicted by a resource supply shift in the lower graph from S1

 back to S0. The shaded area 

is the total monetary cost of funding the supply shift. For example, if 2 acres of wetland 

enhancement are estimated to compensate for an incident that temporarily reduced the 

service value of 1 acre of wetland habitat, the cost of performing 2 acres of wetland 

enhancement becomes the estimate of damages. 

It is clear from Figure 1 that the public’s valuation of the resource (the shaded area in the 

top graph) is not necessarily equal to the total replacement cost (the shaded area in the 

bottom graph). This is especially true when unique resources or rare species are involved, 

as the slope of the aggregate demand curve (top figure) may be much steeper due to 

resource scarcity. This would result in a much larger monetary payment being necessary 

to compensate the public. In such a case, the replacement cost approach of REA may 

result in damages far less than the losses as valued by the public. However, because it is 

easier and less costly to measure the total replacement cost than the total public value, 

REA has an advantage over other methods, especially for small to medium-sized 

incidents with minimal impact on rare species. 

Resource Equivalency Analysis

In this assessment, REA has been used to determining compensatory damages. This 

method is relatively inexpensive and relies primarily on biological information collected 

in the course of determining natural resource injuries caused by the spill. It is consistent 

with approaches recommended in the language of the Comprehensive Environmental 

Response, Compensation and Liability Act (CERCLA) and the Oil Pollution Act of 1990 

(OPA). 

REA involves determining the amount of “natural resource services” that the affected 

resources would have provided had it not been injured, and it equates the quantity of lost 

services with those created by proposed compensatory restoration projects that would 

provide similar services. The unit of measure may be acre-years, stream feet-years, or 

some other metric. The size of the restoration project is scaled to the injury first; the cost 

of restoration is then calculated after the scaling has been done. The cost of restoring a 

comparable amount of resources to those lost or injured is the basis for the compensatory 

damages. In this sense, REA calculates the replacement cost of the lost years of natural 

resource services. 
 A-3 

Future years are discounted at 3% per year, consistent with National Oceanic and 

Atmospheric Administration recommendations for natural resource damage assessments. 

Discounting of future years is done based on the assumption that present services are 

more valuable than future services. When it comes to natural resources, the question of 

whether or not society should value the present more than future is a philosophical 

question (e.g., one can recall the “greenhouse effect” and the question of how much 

expense we should incur today to preserve the future). However, the question of how 

much society actually discounts the value of future natural resources is an empirical one. 

The 3% figure is currently the standard accepted discount rate for natural resource 

damage assessments. 

REA involves three steps: 1) the debit calculation, 2) the credit calculation, 3) the 

computation of the costs of restoration. These calculations may be done in a variety of 

ways, but the most common are to estimate the injury and the restoration benefits in 

terms of area years of habitat or animal years. 

Habitat Example

For example, suppose a 10-acre area is degraded due to an oil spill such that it supplies 

only 30% of its previous habitat services during the year following the incident. In the 

second year after the incident, the habitat begins to recover, supplying 90% of its baseline 

services. By the third year it is fully recovered. In this case, the lost acre years of habitat 

services would be 70% x 10 acres x 1 year + 10% x 10 acres x 1 year = 8 acre years of 

habitat services. Figure 2 illustrates this example by showing the recovery path of the 

habitat over time. 

As stated above, future years are discounted at a 3% rate, thus the injuries in the second 

year count a little less. Incorporating this, 7.97 acre years of habitat services were lost. 

This difference appears minimal here, but becomes significant (due to compounding) if 

injuries persist many years into the future. 

The credit calculation focuses on the gain in habitat services that result from a restoration 

project. Creating acre years of habitat services is a function of both area and time. 

Hypothetically, compensation could involve taking 7.97 acres of land with no habitat 

value (e.g., a parking lot) and turning it into productive habitat for 1 year. Alternatively, 

we could achieve compensation by creating 1 acre for 7.97 years. In reality, most 

restoration projects involve taking previously degraded habitat (at another nearby 

location) and restoring it over a number of years, and maintaining it into the future. 
 A-4 

Suppose the restoration project improves the quality of a nearby degraded area, so that, if 

it previously provided only 30% of potential services, it would provide 80% of potential 

habitat services after restoration. Also suppose the project begins two years after the 

incident and it takes an additional 5 years for the 80% level to be achieved. Figure 3 

provides an illustration of this restoration trajectory. In our hypothetical example, the 

project is expected to have a lifespan of 20 years. Note that, with future years discounted, 

the 20th year of the project (22-23 years after the incident) counts little; years after that 

are effectively completely discounted due to uncertainty regarding the future. 

Mathematically, we seek to restore an area that will provide 7.97 acre years of services 

over the discounted 20-year phased-in life span of the restoration project. In this 

example, that would be an area of about 1.3 acres. That is to say, restoration of 1.3 acres 

for 20 years would compensate the public for the 7.96 lost acre years of habitat services 

due to the spill. Visually, the area identified in Figure 3 (multiplied by the affected acres 

and calculated to measure the present discounted value) should equal the area identified 

in Figure 4 (again, multiplied by the acres targeted for restoration and calculated to 

measure the present discounted value, thus discounting future years). 

The percentage of habitat services lost (or gained, in the case of the restoration project) 

may be measured in a variety of ways. For our hypothetical oil spill case, three examples 

might include (1) the use of a habitat-wide evaluation index, (2) the use of one or more 

surrogate species, or (3) the use of an estimate based on the degree of oiling. Care must 

be taken when using a surrogate species to represent the entire affected habitat. Ideally, 

this surrogate is the population of one or more species that is immobile (that is, the 

animals do not move easily in and out of the affected area) and that has significant 

forward and/or backward ecological links to other species in the affected ecosystem. For 

example, the population of red crossbills, a bird that feeds primarily on pine cone seeds 

and migrates erratically from year to year, would be a poor surrogate for measuring 

injuries to a streambed. The aquatic macroinvertebrate community within the stream, 

however, provides an ideal surrogate, as they play a key role in the streambed food chain. 

Likewise, on the restoration side, care must taken when the project targets one or a few 

species rather than the entire habitat. Ideally, a project that seeks to restore the 

population of a key indicator species will also benefit the entire habitat and, thus, other 

species as well. Indeed, such projects typically focus directly on habitat improvements. 

However, it is important to verify that such a species-centered project is indeed benefiting 

the entire habitat. 

Animal Example 

When the injury is primarily to individual animals rather than a complete habitat, the 

REA may focus on lost animal-years. For example, suppose an oil spill causes negligible 

injury to a body of water, but results in the death of 100 ducks. Using information about 

the life history of the ducks (e.g., annual survival rate, average life expectancy, average 

fledging rate, etc.), we can estimate the “lost duck years” due to the spill. On the credit 

side, we can examine restoration projects designed to create duck nesting habitat and 

scale the size of the project such that it creates as many duck years as were lost in the 

incident. 
 A-5 

Restoration Costs = Natural Resource Damages

Once the proposed restoration projects are scaled such that they will provide services 

equal to those lost due to the incident, the cost of the projects can be calculated. Note 

that this is the first time dollar figures enter the REA process. Until now, all the 

calculations of the “equivalency” have been in terms of years of resource services. The 

cost of the restoration projects is the compensatory damage of the incident. 

Prepared by: 

Steve Hampton, Ph.D. 

Resource Economist 

California Department of Fish and Game 

(916) 323-4724 

shampton@ospr.dfg.ca.gov 

Matthew Zafonte, Ph.D. 

Resource Economist 

California Department of Fish and Game 

(916) 323-0635 

mzafonte@ospr.dfg.ca.gov 

Revision Date: January 14, 2003 

For another explanation of the REA methodology (in its more specific form for habitats), 

see “Habitat Equivalency Analysis: An Overview”, prepared by NOAA. Copies of this 

document are available at http://www.darp.noaa.gov/library/pdf/heaoverv.pdf. 
 A-6 

GLOSSARY 

Aggregate demand 

 the demand of all consumers combined; e.g., if there are 20,000 

people in a town and each person demands two pieces of bread each 

day, the aggregate demand is 40,000 pieces of bread per day. 

Compensatory restoration 

 a restoration project which seeks to compensate the public for 

temporal or permanent injuries to natural resources; e.g., if a marsh is 

injured by an oil spill and recovers slowly over ten years, a 

compensatory project (which may be off site) seeks to compensate the 

public for the ten years of diminished natural resources. 

Discount rate 

 the rate at which the future is discounted, i.e., the rate at which the 

future does not count as much as the present; e.g., a dollar a year from 

now is worth less than a dollar today; if the bank offers a 3% rate, 

whereby $1.00 becomes $1.03 in one year, the future was discounted 

at 3%. 

Primary restoration 

 a restoration project which seeks to help an injured area recover more 

quickly from an injury; e.g., if a marsh is injured by an oil spill and 

would recover slowly over ten years if left alone, a primary 

restoration project might seek to speed the recovery time of the marsh 

and achieve full recovery after five years. 

Replacement cost 

 the cost of replacing that which was lost; e.g., if fifty acre-years of 

habitat services were lost due to an oil spill, the cost of creating fifty 

acre-years of similar habitat services would be the replacement cost. 
 B-1 

Appendix B: Bird Mortality Summary

ESTIMATED MORTALITY BY SPECIES AND SPILL EVENT 

Species/Groups 

Winter 

1990-91 

Winter 

1992-93 

Chronic 

1993-

1997 

Winter 

1997-98 

Chronic 

1998-

2001 

2001 - 

2003 TOTAL 

Waterfowl 7 0 1 835 2 17 862 

Loons 129 0 2 843 14 326 1,314 

Grebes 327 0 5 2,897 10 867 4,106 

Procellarids 6 0 5 4,749 21 15 4,796 

Brown Pelicans 22 0 0 198 2 56 278 

Cormorants 209 0 1 711 10 529 1,460 

Gulls 317 0 5 1,256 9 801 2,388 

Snowy Plovers 2 0 0 23 0 5 30 

Phalaropes 18 0 0 1,490 0 46 1,554 

Other Shorebirds 12 0 2 0 0 31 45 

Common Murre 2,348 47 37 23,152 63 6,159 31,806 

Marbled Murrelet 4 0 0 32 0 9 45 

Ancient Murrelet 42 0 0 281 0 105 428 

Cassin's Auklet 31 0 0 1,395 5 78 1,509 

Rhino. Auklet 59 0 1 379 5 149 593 

Other Alcids 5 0 1 212 2 13 233 

Land Birds 2 0 0 2 0 5 9 

Other / Unknown 1 0 0 107 2 3 113 

TOTAL 3,541 47 60 38,562 145 9,214 51,569 

These figures include the totals estimated by the Beached Bird Model and other methods 

(for Snowy Plover and Marbled Murrelet), as described in Section 4.2.1.1. 
 C-1 

Appendix C: Methods for Calculating Lost Bird-Years 

Lost bird-years were calculated several different ways, depending upon the species. 

Theoretically, lost bird-years are the difference between two different population 

trajectories: without the spills (baseline) and with the spills (injured). Without 

restoration, the two trajectories only converge (i.e. the injured population only recovers to 

baseline levels) if there is a natural compensating mechanism dependent upon population 

size (at least at the local, or colony, level). Thus, the calculation of lost bird-years must 

be consistent with a biological explanation of natural recovery over time (or lack thereof) 

(Zafonte and Hampton 2005). 

For most bird species, the Single-Generation Stepwise Replacement Model was used to 

calculate lost bird-years. This approach is described below. For the Ashy Storm-Petrel, 

Common Murre, and Marbled Murrelet, a location-specific population model was used. 

Those will be described in the relevant appendices. For all bird-year calculations, a 3% 

discount rate is employed (discounted to the year 2006), consistent with common practice 

in natural resource damage assessments (e.g., see NOAA 1999). 

The demographic parameters used in the bird REAs are drawn from one or more of the 

citations listed. In many instances, some parameters were adjusted (within the range of 

that reported in the literature) so that the overall population was calibrated appropriately 

to avoid implying unrealistic rates of increase or decrease. 

Single-Generation Stepwise Replacement Model

The single-generation stepwise replacement approach to calculating lost bird-years 

assumes that each year after a spill the juvenile age class will be entirely replaced. That 

is, despite the fact that some breeding adults have been killed, the population produces 

the same number of juveniles post-spill as it did pre-spill. Biologically, this could occur if 

the population was at carrying capacity with respect to breeding opportunities (perhaps 

limited by available nesting habitat or food base during the nesting season). The loss of 

some adults would open up room for other adults (i.e. “floaters”) to take over the vacant 

nesting opportunities and thus maintain the population’s annual production of juveniles. 

Thus, the youngest age class impacted by the spill will fully recover to its pre-spill level 

after the next breeding season. The second-year age class will fully recover two years 

after the spill, as the recovered first-year birds grow older. Likewise, the third-year age 

class will fully recover after three years, and so on. Mathematically, this is equal to 

calculating the number of years lost by the killed birds, based on the life expectancy of 

each age class. Details regarding the demographic parameters used to calculate lost bird 

years are presented in the relevant appendices for each species below. 

This method roughly follows the same approach as used by Sperduto et al.(1999, 2003) 

for calculating “direct loss” for birds with “extended” recovery times in the North Cape

oil spill NRDA. Calculations are based upon the following assumptions: 

Assumption 1: Acute spill mortality is distributed proportionately across the 

various age classes of the injured population. In this case, Nevins and Carter’s 
 C-2 

(2003) examination of Common Murres collected dead during the Point Reyes 

Tarball Incidents supports this assumption. 

Assumption 2: Rates of juvenile and adult survivorship are constant before and 

after the spill. 

Assumption 3: The pre-spill and fully recovered populations are roughly constant 

in size and stable in age-distribution, as determined by demographic 

characteristics of the species (specifically survivorship and fecundity). 

Assumption 4: There is a maximum age beyond which no birds live. 

Assumption 5: Surviving adult birds match the total reproductive output that the 

surviving and impacted birds would have had in the breeding seasons after the 

spill had the spill not occurred (i.e. the number of post-spill nests equals the 

number of baseline nests). This could occur because of non-breeding “floaters” in 

the area, reduced competition for high quality nesting sites, or decreased 

competition for foraging around the breeding area.

Figure 1 provides an example of how these assumptions combine to describe biological 

recovery in a hypothetical population with three one-year age classes. Year -1 depicts the 

population’s pre-spill conditions. Year 0 shows population numbers prior to the first full 

year after the spill. The shaded area is the number of each age class killed, which is 

distributed proportionately between age classes (Assumption 1). The arrows describe 

how the recovered birds advance through each age class. 

0

20

40

60

80

100

Year -1 Year 0 Year 1 Year 2 Year 3 Year 4

Population Size

Age 0

Pre-Spill Full Recovery

Lost

Lost Lost

Lost Lost Lost

Age 1

Age 2

Recovered Recovered Recovered

Recovered Recovered

Recovered

Recovered

Recovered

Recovered

(Die of Old Age)

Figure 1: Recovery by Age Class over Time

In Year 1, the number of fledglings replaces the losses to the first age class (Assumption 

5). The age classes from Year 0 all face annual mortality, with complete mortality for the 

third age class. This process continues in Year 2, with the recovered Age 0 juveniles from 
 C-3 

Year 1 facing mortality and growing one year older to reach Age 1. In Year 3, there is 

full recovery. These calculations do not include impacts to future generations of birds 

(i.e., “indirect loss” as considered by Sperduto et al.1999, 2003). 
 D-1 

Appendix D: Loon/Kokechik Flats REA Details 

INJURY CALCULATION

Because breeding populations of the Pacific Loon, in particular, are thought to be limited 

by nest site availability (see Russell 2002), the Trustees applied the single-generation 

stepwise replacement approach to calculating lost bird-years as described in Appendix C. 

A lost bird-year multiplier (i.e. lost bird-years per bird killed) is first calculated, and then 

applied to the mortality events from the various years, discounted to 2006. 

The North Cape REA (Spertudo et al. 2003) calculates injuries to loons based upon 

Common Loon demographics. While data on Pacific Loons is limited, the demographic 

parameters likely do not vary meaningfully for this analysis. The following set of 

roughly stationary demographic parameters is based upon their analysis: 

 Age of First Breeding: 5 Years Old

 Female Offspring per Female (Annual): 0.27 (fecundity = 0.54)

 Survivorship (From fledge to one year of age): 76%

 Survivorship (Age 1+): 88.5%

 Maximum Age: 24 Years Old

The only difference between these parameters and those used by Sperduto et al. (2003) is 

that annual survivorship beyond the first year has been increased 0.5%. This adjusts the 

implied loon life history to maintain an approximately constant population size. These 

parameters are consistent with data from studies summarized in McIntyre and Barr 

(1997) (for Common Loons), Barr et al. (2000) (for Red-throated Loons), and Russell 

(2002) (for Pacific Loons). The result is that the bird-year multiplier is 6.29. 

This multiplier is then applied to the various mortality events, discounted to 2006. 

Spill Event

Estimated 

Mortality 

Discounted Lost 

Bird-Years 

winter 1990-91 129 1,265 

chronic 1993-97 2 17 

winter 1997-98 843 6,722 

chronic 1998-2001 14 102 

2001-2003 326 2,242 

TOTAL 1,314 10,348 

Total discounted lost bird-years for loons: 10,348. 

CREDIT CALCULATION (projected restoration benefits) 

Based on aerial surveys of Pacific and Red-throated Loons at Kokechik Flats, the 

Trustees estimated that the project will benefit approximately 360 loon nests. Benefits 

per nest, in terms of increased productivity (or increased nest density) are difficult to 

estimate, as no data exists from this area. In Sperduto et al. (2003), a project in New 

England to protect loon nests from disturbance was assumed to generate an additional 

0.50 fledglings per nest, or almost triple fecundity (from 0.27 to 0.77). This equates to 

some of the highest productivity estimates for loons (McIntyre and Barr 1997). The 
 D-2 

Trustees consider that level of gains as an upper bound, and believe that a figure 

approximately half of that (i.e. an increase of 0.25 fledglings per nest) would be more 

realistic. The REA restoration benefits offset the injury when the project lasts 10 years 

and the benefits are 0.32 fledglings per nest. The Trustees believe this is a reasonable 

estimate. Even though the project only provides funding for 10 years, it is anticipated 

that, even if enforcement were to cease entirely, residual benefits via public education 

would provide benefits (at a declining rate) for an additional 15 years. This is 

incorporated into the credit calculations. 

Year

Protected 

Nests 

Increased 

Fledges 

Increased 

Bird-Years 

Discounted 

to 2006 

2007 360 115 703 703 

2008 360 115 703 683 

2009 360 115 703 663 

2010 360 115 703 644 

2011 360 115 703 625 

2012 360 115 703 607 

2013 360 115 703 589 

2014 360 115 703 572 

2015 360 115 703 555 

2016 360 115 703 539 

2017 360 108 659 491 

2018 360 101 615 444 

2019 360 94 571 401 

2020 360 86 527 359 

2021 360 79 483 320 

2022 360 72 439 282 

2023 360 65 396 246 

2024 360 58 352 213 

2025 360 50 308 181 

2026 360 43 264 150 

2027 360 36 220 122 

2028 360 29 176 94 

2029 360 22 132 69 

2030 360 14 88 45 

2031 360 7 44 22 

 

Based on 

increase of 

0.32 fledges 

per nest. 

Based on 

6.104 birdyears per 

fledge (life 

expectancy 

of a fledge) 

Discounted 

at 3% per 

year 

Total: 9,616 

This project, protecting 360 nests for 10 years, approximately compensates for the lost 

bird-years. Given the uncertainties in estimating project benefits, the Trustees consider 

this sufficient to compensate for the injuries. This project will simultaneously benefit 

thousands of phalarope and waterfowl nests, providing sufficient restoration for those 

species as well. 
 E-1 

Appendix E: Grebe/Colony Protection REA Details

INJURY CALCULATION

Because breeding populations of the Western Grebe, in particular, may be limited by 

suitable nest colony sites, the Trustees applied the single-generation stepwise 

replacement approach to calculating lost bird-years as described in Appendix C. A lost 

bird-year multiplier (i.e. lost bird-years per bird killed) is first calculated, and then 

applied to the mortality events from the various years, discounted to 2006. 

Data on Western Grebes is limited. Storer and Nuechterlein (1992) assume that most 

birds breed in their first year. Data from Clear Lake suggests that, in good years without 

nest colony disturbance, productivity is approximately 1.0 fledges/nest (D. Anderson, 

pers. comm.) (or 0.5 female offspring per female). The following set of demographic 

parameters imply an approximately constant population size: 

 Age of First Breeding: 1 Year Old

 Female Offspring per Female (Annual): 0.50 (fecundity = 1.00)

 Survivorship (From fledge to one year of age): 60%

 Survivorship (Age 1+): 70%

 Maximum Age: 20 Years Old

These parameters are consistent with data from information summarized in Storer and 

Nuechterlein (1992). The result is that the bird-year multiplier is 3.01. 

This multiplier is then applied to the various mortality events, discounted to 2006. 

Spill Event

Estimated 

Mortality 

Discounted Lost 

Bird-Years 

winter 1990-91 327 1,533 

chronic 1993-97 5 21 

winter 1997-98 2,897 11,046 

chronic 1998-2001 10 35 

2001-2003 867 2,852 

TOTAL 4,106 15,487 

Total discounted lost bird-years for grebes: 15,487. 

CREDIT CALCULATION (projected restoration benefits) 

For project scaling, the Trustees focused on one of the targeted lakes, Clear Lake, where 

data is available. The project will benefit approximately 940 grebe nests at Clear Lake. 

Benefits per nest may be calculated using data collected by Dan Anderson of UC Davis. 

In 13 years of surveys, Anderson noted that 7 years featured good production, with an 

average of 1.0 fledges/nest. The other 6 years were marred by disturbance events, in 

which nest productivity plummeted, averaging only 0.2 fledges/nest. This equates to an 

overall average of 0.63 fledges/nest. Assuming the project is 80% successful in 

eliminating these disturbance events and maintaining annual average productivity at 0.5 

fledges per nest, the benefits per nest from the project will be 0.30 fledges/nest. 
 E-2 

Year

Protected 

Nests 

Increased 

Fledges 

Increased 

Bird-Years 

Discounted 

to 2006 

2007 940 278 782 782 

2008 940 278 782 759 

2009 940 278 782 737 

2010 940 278 782 716 

2011 940 278 782 695 

2012 940 278 782 675 

2013 940 278 782 655 

2014 940 278 782 636 

2015 940 278 782 618 

2016 940 278 782 600 

 

Based on 

increase of 

0.30 fledges 

per nest. 

Based on 

2.817 birdyears per 

fledge (life 

expectancy 

of a fledge) 

Discounted 

at 3% per 

year 

Total: 6,873 

This project, protecting nests for 10 years, compensates for approximately half of the lost 

bird-years. The Trustees propose two similar projects: a 10-year project focused on Clear 

Lake and a 10-year project focused on other lakes (e.g., Eagle Lake, Lake Almanor, Tule 

Lake NWR, and the Thermolito Forebay) where the benefit/cost ratio is expected to be 

similar. 
 F-1 

Appendix F: Procellarid/Farallon Islands and Taiaroa Head REA Details 

INJURY CALCULATION

For lost bird-year calculations, Procellarids were divided into fulmars, shearwaters, and 

storm-petrels. Lost bird-years were calculated separately for each group. 

For fulmars and shearwaters, the Trustees applied the single-generation stepwise 

replacement approach to calculating lost bird-years as described in Appendix C because 

breeding populations of most shearwaters appear limited by suitable nest colony sites, 

while fulmars appear limited by food availability (Hatch and Nettleship 1998). A lost 

bird-year multiplier (i.e. lost bird-years per bird killed) is first calculated, and then 

applied to the mortality events from the various years, discounted to 2006. The 

demographic parameters used for the Northern Fulmar were calibrated to imply a roughly 

constant population size: 

 Age of First Breeding: 5 Years Old

 Female Offspring per Female (Age 5): 0.013

 Female Offspring per Female (Age 6): 0.026 

 Female Offspring per Female (Age 7): 0.039 

 Female Offspring per Female (Age 8): 0.053 

 Female Offspring per Female (Age 9): 0.066 

 Female Offspring per Female (Age 10): 0.079 

 Female Offspring per Female (Age 11): 0.092 

 Female Offspring per Female (Age 12): 0.105 

 Female Offspring per Female (Age 13): 0.118 

 Female Offspring per Female (Age 14): 0.131 

 Female Offspring per Female (Age 15): 0.144 

 Female Offspring per Female (Age 16): 0.158 

 Female Offspring per Female (Age 17): 0.171 

 Female Offspring per Female (Age 18): 0.184 

 Female Offspring per Female (Age 19): 0.197 

 Female Offspring per Female (Age 20+): 0.21 

 Annual Survivorship (Age 69-70): 6.9%

 Annual Survivorship (Age 68-69): 16.9%

 Annual Survivorship (Age 67-68): 26.9%

 Annual Survivorship (Age 66-67): 36.9%

 Annual Survivorship (Age 65-66): 46.9%

 Annual Survivorship (Age 64-65): 56.9%

 Annual Survivorship (Age 63-64): 66.9%

 Annual Survivorship (Age 62-63): 76.9%

 Annual Survivorship (Age 61-62): 86.9%

 Annual Survivorship (Age 5-6 to 60-61): 96.9%

 Annual Survivorship (Age 4-5): 89.6%

 Annual Survivorship (Age 3-4): 82.4%

 Annual Survivorship (Age 2-3): 75.1%

 Annual Survivorship (Age 1-2): 67.9%
 F-2 

 Survivorship (From fledge to one year of age): 60.6%

 Maximum Age: 70 Years

To calibrate the model, we assumed that the survivorship from Ages 0-1 to 4-5 increased 

linearly each year such that 96.9% adult survivorship was achieved at Age 5-6. We then 

calibrated Age 0-1 survivorship so that the sequence was consistent with a population 

maintaining a constant population size. The result is that the bird-year multiplier for 

fulmars is 12.70. 

This multiplier is then applied to the various mortality events, discounted to 2006. 

Spill Event

Estimated 

Mortality 

Discounted Lost 

Bird-Years 

winter 1990-91 6 119 

chronic 1993-97 5 88 

winter 1997-98 4,449 71,785 

chronic 1998-2001 21 309 

2001-2003 15 208 

TOTAL 4,496 72,509 

For shearwaters, the demographic parameters were calibrated to a slightly declining 

population (about 0.5% annually): 

 Age of First Breeding: 6 Years Old

 Female Offspring per Female: 0.4 (fecundity = 0.8)

 Annual Survivorship (Age 3-4+): 90%

 Annual Survivorship (Age 2-3): 85%

 Annual Survivorship (Age 1-2): 70%

 Survivorship (From fledge to one year of age): 60%

 Maximum Age: 40 Years

The result is that the bird-year multiplier for shearwaters is 6.61. 

This multiplier is then applied to the various mortality events, discounted to 2006. For 

ease of calculation, all 266 birds were assumed killed in 1997-1998, implying 2,228 total 

discounted lost bird-years. 

For storm-petrels, the Trustees utilized a Farallon Island-specific model of the Ashy 

Storm-Petrel described in the credit calculation below, assuming that 21 Ashy StormPetrels and 13 Least Storm Petrels were killed (all in 1997-98 for ease of computation). 

The result is that 1,044 discounted storm-petrel-years were lost. 

In summary: 

• total discounted lost bird-years for fulmars = 72,509 

• total discounted lost bird-years for shearwaters = 2,228

• total discounted lost bird-years for storm-petrels = 1,044

The total discounted lost bird-years for all Procellarids: 75,781 
 F-3 

CREDIT CALCULATION (projected restoration benefits) 

The Trustees have selected two restoration projects to address Procellarids. These 

projects will benefit Sooty Shearwaters in New Zealand and Ashy Storm-Petrels at the 

Farallon Islands. 

Despite the lack of suitable project for fulmars, this approach still maintains fair 

compensation for Procellarids as a whole. The Trustees have selected this approach for 

the following reasons: 

1. it focuses restoration on storm-petrels, which face the most critical conservation 

needs; 

2. it is the least cost alternative, as additional fulmar restoration is relatively 

expensive and with questionable feasibility; 

3. these projects are “lumpy” and not easily divisible; and 

4. it is in response to public comments (see Appendix N). 

Farallon Islands

For scaling the Farallon Islands project, the Trustees focused on potential increases in the 

Ashy Storm-Petrel population breeding at the Farallon Islands, using a species and 

location-specific population model. The Ashy Storm-Petrel model relied on demographic 

parameters estimated from data collected at the Farallon Islands. These islands are home 

to over half of the world’s population of the species, almost certainly the source location 

for the impacted birds, and the location of the restoration project. The sources of the data 

are Sydeman et al. (1998) and Nur et al. (1999). The parameters have been calibrated so 

that the population falls from 6,461 birds in 1972 to approximately 4,284 birds in 1992, 

consistent with estimates from Sydeman et al. (1992). 

 Age of First Breeding: 5 Years Old

 Female Offspring per Female: 0.338 (fecundity = 0.676)

 Annual Survivorship (Age 3-4+): 88%

 Annual Survivorship (Age 2-3): 85%

 Annual Survivorship (Age 1-2): 70%

 Survivorship (From fledge to one year of age): 60%

 Maximum Age: 40 Years

The restoration project will eradicate non-native mice from the islands. This, in turn, will 

affect productivity, by ending mouse predation of eggs and chicks, and the annual 

survival rate of adults, by decreasing predation by Burrowing Owls. The project may 

impact those parameters in these ways: 

 Female Offspring per Female: increases 5% to 0.355 

 Annual Survivorship (Age 4-5+): increases from 88.0% to 90.2% (this would 

imply that current Burrowing Owl predation is approximately 42 birds per year, 

given the Ashy Storm-Petrel breeding population of about 1,500 birds on the 

Farallon Islands). 

These changes would stop the current population decline and cause the population to 

exactly stabilize. The model assumed project benefits would begin in 2008 and continue 

through 2100. The assumption of the long-term benefits is based upon the Trustees’ 
 F-4 

confidence that the islands will remain free of introduced species through the oversight of 

the Farallon NWR. The model calculates that the project will generate 36,277 bird-years. 

Using alternative and more optimistic parameters whereby the project causes productivity 

to increase 10% (to 0.371 female offspring per female) and annual survivorship to 

increase to 90.8% (implying the current Burrowing Owl predation is approximately 50 

birds per year), the storm-petrel population would begin to increase at approximately 1% 

per year and generate 57,390 bird-years through 2100. 

This range of project benefits may be conservative. Some recent estimates suggest that 

Burrowing Owls have taken 100 to 200 adult Ashy Storm-Petrels annually in recent years 

(J. Irwin, pers. comm.), suggesting a more precipitous population decline than in the past 

(i.e., between 1972 and 1992) and thus the potential for even greater restoration benefits. 

Because no population surveys are available to confirm a steeper decline since 1992, the 

model used here mimics the earlier documented rate of decline. 

New Zealand

For scaling the Taiaroa Head colony protection project, the Trustees used the same 

approach as with the Farallon project, focusing on increases in productivity and adult 

survivorship for Sooty Shearwaters. The same demographic parameters as described 

above were used, except with the following changes to fecundity and adult survival to 

mimic the 4.3% annual decline of the Taiaroa Head colony caused by depredation of 

nests and adults. 

 Female Offspring per Female: 0.3 (fecundity = 0.6)

 Annual Survivorship (Age 3-4+): 87.5%

The restoration project will protect the nesting colony from depredation of nests and 

adults by non-native mammals. Thus, both productivity and annual adult survival should 

increase, enabling the colony to stabilize at its current size, rather than decrease at 4.3% 

per year. The project may thus impact the parameters in these ways: 

 Female Offspring per Female: increases 20% to 0.36 

 Annual Survivorship (Age 4-5+): increases from 87.5% to 90.9% 

These changes would stop the current population decline and cause the population to 

stabilize and slightly increase over time. The model assumed project benefits would 

begin in 2008 and continue through 2100. The model calculates that the project will 

generate 13,334 bird-years. Under the most optimistic scenario, where productivity 

increases to 0.4 female offspring per female, the colony would increase in size and 

produce 17,922 bird-years. 

Summary

Combining the range of projected benefits from the two projects, they will generate 

49,611 to 75,312 gained bird-years. While most of this range is below the estimated 

74,835 lost bird-years, the Ashy Storm-Petrel model may be conservative for reasons 
 F-5 

described above, and thus that project may produce greater benefit than the range 

presented here. The Trustees believe these two projects will address the injury to 

Procellarids. 
 G-1 

Appendix G: Pelican, Cormorant, and Cassin’s Auklet/Baja California Islands 

REA Details

INJURY CALCULATION

Because the pelicans and cormorants breeding along the Pacific coast of Baja California, 

where the restoration actions will take place, appear to be limited by suitable disturbancefree nest sites, the Trustees applied the single-generation stepwise replacement approach 

to calculating lost bird-years as described in Appendix C. This provides a rather 

conservative estimate, as there is considerable speculation that most sub-populations of 

pelicans and cormorants are limited by density-independent events such as food supply 

induced by oceanographic events (Shields 2002; D. Anderson, pers. comm., Wallace and 

Wallace 1998). In such situations, it is most correct to use the injury-into-perpetuity 

approach when calculating lost bird-years (Zafonte and Hampton 2005), which would 

have generated nearly five times as many lost bird-years. All losses were discounted to 

2006. 

For Cassin’s Auklets, the Trustees also applied the single-generation stepwise 

replacement approach because breeding populations appear limited by suitable nest sites 

(Manuwal and Thoresen 1993). For example, Cassin’s Auklets studied at the Farallon 

Islands are believed to have substantial numbers of non-breeding floaters, consistent with 

limitations on nest sites. 

Estimates of annual productivity (fledges/pair) for cormorants and auklets was based 

upon 32-year means from data collected for Brandt’s Cormorants and Cassin’s Auklets at 

the Farallon Islands (Warzybok et al. 2003). Annual productivity for pelicans is based 

upon Anderson et al. (1982). For Brown Pelican data, we relied upon Williams and 

Joanen (1974) and Anderson et al. (1996). For cormorants, we relied upon Wallace and 

Wallace (1998) and Hatch and Weseloh (1999). For Cassin’s Auklets, little data exists 

on annual survivorship. We used known information on age of first breeding and a longterm mean on annual productivity from the Farallon Islands (Warzybok et al. 2003). We 

then calibrated annual survival based upon other alcids and subject to the constraint that 

the population be constant. 

Brown Pelicans

 Age of First Breeding: 3 Years Old

 Female Offspring per Female: 0.33 (fecundity = 0.66)

 Annual Survivorship (Age 3-4+): 88%

 Annual Survivorship (Age 2-3): 80%

 Annual Survivorship (Age 1-2): 72%

 Survivorship (From fledge to one year of age): 64%

 Maximum Age: 34 Years

Cormorants (based on Brandt’s and Double-crested Cormorant)

 Age of First Breeding: 4 Years Old (plus 50% of 3 year-olds)

 Female Offspring per Female: 0.725 (fecundity = 1.45)

 Annual Survivorship (Age 2-3+): 80%

 Annual Survivorship (Age 1-2): 77% 
 G-2 

 Survivorship (From fledge to one year of age): 50%

 Maximum Age: 18 Years

Cassin’s Auklet

 Age of First Breeding: 3 Years Old 

 Female Offspring per Female: 0.36 (fecundity = 0.72)

 Annual Survivorship (Age 2-3+): 87.1%

 Annual Survivorship (Age 1-2): 70%

 Survivorship (From fledge to one year of age): 60% 

 Maximum Age: 30 Years

The results are that the bird-year multiplier is 5.97 for pelicans, 3.89 for cormorants, and 

5.65 for Cassin’s Auklets. 

These multipliers were then applied to the various mortality events, discounted to 2006. 

Pelicans Cormorants Cassin’s Auklets 

Spill Event

Estimated 

Mortality 

Discounted 

Lost 

Bird-Years 

Estimated 

Mortality 

Discounted 

Lost 

Bird-Years 

Estimated 

Mortality 

Discounted 

Lost 

Bird-Years 

winter 1990-91 22 205 209 1,267 31 273 

chronic 1993-97 0 0 1 5 0 0 

winter 1997-98 198 1,498 711 3,504 1,395 9,986 

chronic 1998-2001 2 14 10 45 5 33 

2001-2003 56 366 529 2,249 78 482 

TOTAL 278 2,083 1,460 7,070 1,509 10,773 

Total discounted lost bird-years for pelicans: 2,083 

Total discounted lost bird-years for cormorants: 7,070 

Total discounted lost bird-years for Cassin’s Auklets: 10,773 

CREDIT CALCULATION (projected restoration benefits) 

For project scaling, the Trustees focused on potential increases in populations at islands 

off the Pacific Coast of Baja California, Mexico (or prevention of decreases). By 

removing disturbance and opening up these islands as suitable nesting habitat, the project 

will protect existing populations from further disturbances and allow them to expand and 

take advantage of new nesting areas at these islands. The benefits will be for Brown 

Pelicans, cormorants, and Cassin’s Auklets. 

To calculate benefits, we assumed a population growth rate of at least 10 new nests per 

year for each species on each island, or colony growth of 3% per year, whichever was 

larger (or alternatively, the protection of 150 Cassin’s Auklet nests/year at San Jeronimo 

and 1,000 nests/year at West San Benito that could otherwise be destroyed by human 

disturbance). If no birds were currently present on an island, but the project anticipated 

attraction of them, the starting point for the benefits trajectory was 10 nests beginning in 

2008. 
 G-3 

For each island, the number of increased nests, increased fledges, and increased birdyears from those fledges was estimated for the duration of the 6-year project. 

The results, as well as the current breeding populations with each island, are presented in 

the table below. Gained nests refer to the estimated number of new (or protected but 

otherwise lost) nests created as a result of the project. This number increases over time in 

cases where we anticipate population increases. Thus, “10 to 60” would mean 10 new 

nests at the beginning of the project, and 60 new nests at the end, after six years. The 

calculations assume that benefits begin in 2008, and all benefits are discounted to 2006. 

ISLAND PELICANS CORMORANTS CASSIN’S AUKLETS 

Current # nests 200 625 1,500 San Martín Gained nests 10 to 60 19 to 121 45 to 291 

Current # nests 0 20 5,000 San Jeronimo Gained nests 0 10 to 60 150 

Current # nests 200 142 35,000 San Benito Gained nests 10 to 60 10 to 60 1,000 

Current # nests 55 800 10 Natividad Gained nests 10 to 60 24 to 155 10 to 60 

Current # nests 10 100 10 San Roque Gained nests 10 to 60 10 to 60 10 to 60 

Current # nests 0 10 10 Asunción Gained nests 0 10 to 60 10 to 60 

TOTAL GAINED NESTS: 40 to 240 83 to 517 1,225 to 1,621 

FLEDGES PER NEST: 0.66 1.45 0.72 

BIRD-YEARS PER FLEDGE: 4.36 3.09 4.13 

TOTAL GAINED BIRD-YEARS 

(discounted to 2006): 2,.067 6,831 17,152 

The results show that the project will provide 99% of the compensation needed for 

injuries to pelicans, 97% of that required for cormorants, and 205% of that required for 

Cassin’s Auklets. Given the uncertainty associated with these estimates, the Trustees 

concluded that this project, by addressing the needs of several species simultaneously, 

was the most cost-effective way to provide the needed restoration. 
 H-1 

Appendix H: Snowy Plover/Point Reyes REA Details 

INJURY CALCULATION

Because breeding populations of the Snowy Plover are limited by the availability of 

suitable disturbance-free nest sites (Page et al. 1995), the Trustees applied the singlegeneration stepwise replacement approach to calculating lost bird-years as described in 

Appendix C. A lost bird-year multiplier (i.e. lost bird-years per bird killed) is first 

calculated, and then applied to the mortality events from the various years, discounted to 

2006. 

Data regarding most demographic parameters are derived from Page et al. (1995) and 

data from PRNS. Survivorship from fledging to age one is calibrated to a population 

decline of slightly more than 1% per year. 

 Age of First Breeding: 1 Year Old

 Female Offspring per Female (Annual): 0.50 (fecundity = 1.00)

 Survivorship (From fledge to one year of age): 60%

 Survivorship (Age 1+): 80%

 Maximum Age: 15 Years Old

The result is that the bird-year multiplier is 3.95. 

This multiplier is then applied to the various mortality events, discounted to 2006. 

Mortality by spill event was distributed proportionately according to total estimated bird 

impacts by spill event and is closely correlated to the number of observed oiled Snowy 

Plovers. 

Spill Event

Estimated 

Mortality 

Discounted Lost 

Bird-Years 

winter 1990-91 2 12 

chronic 1993-97 0 0 

winter 1997-98 23 115 

chronic 1998-2001 0 0 

2001-2003 5 22 

TOTAL 30 150 

Total discounted lost bird-years for Snowy Plovers: 150. 

CREDIT CALCULATION (projected restoration benefits) 

The project has been scaled to 30 acres in size. Based on data from the pilot study, this 

will lead to the establishment of at least four nests, generating an equal number (1.0 

fledges per female per year) of fledges each year. Project benefits ramp up over two 

years, the time to implement the project. Because the project budget does not fund ongoing maintenance to control non-native vegetation, project benefits begin to ramp down 

after 8 years, assuming a modest rate of re-colonization by non-native vegetation (2 acres 

per year). 
 H-2 

Year

Restored 

Acres 

New 

Nests 

Increased 

Fledges 

Increased 

Bird-Years 

Discounted 

to 2006 

2007 15 2.0 2.0 7.1 6.9 

2008 30 4.0 4.0 14.2 13.4 

2009 30 4.0 4.0 14.2 13.0 

2010 30 4.0 4.0 14.2 12.6 

2011 30 4.0 4.0 14.2 12.2 

2012 30 4.0 4.0 14.2 11.9 

2013 30 4.0 4.0 14.2 11.5 

2014 30 4.0 4.0 14.2 11.2 

2015 28 3.7 3.7 13.3 10.2 

2016 26 3.5 3.5 12.3 9.2 

2017 24 3.2 3.2 11.4 8.2 

2018 22 2.9 2.9 10.4 7.3 

2019 20 2.7 2.7 9.5 6.4 

2020 18 2.4 2.4 8.5 5.6 

2021 16 2.1 2.1 7.6 4.9 

2022 14 1.9 1.9 6.6 4.1 

2023 12 1.6 1.6 5.7 3.4 

2024 10 1.3 1.3 4.7 2.8 

2025 8 1.1 1.1 3.8 2.2 

2026 6 0.8 0.8 2.8 1.6 

2027 4 0.5 0.5 1.9 1.0 

2028 2 0.3 0.3 0.9 0.5 

2029 0 0.0 0.0 0.0 0.0 

Based on 0.13 

nests/acre 

from the pilot 

study. 

Based on 

increase of 1.0 

fledges per 

nest. 

Based on 3.55 

bird-years per 

fledge (life 

expectancy of 

a fledge) 

Discounted at 

3% per year 

Total: 160 

This project, restoring 30 acres of Snowy Plover nesting habitat, compensates for the lost 

bird-years. 
 I-1 

Appendix I: Common Murre REA Details 

INJURY CALCULATION

Lost bird-years were calculated using a local population model of the Common Murre. 

Because Common Murres are still recovering from historical declines, population growth 

appears to be linked to general oceanic conditions rather than density-dependent factors 

such as nest site availability (N. Nur, pers. comm.). The current central California 

population is approximately 250,000 breeding birds (G. McChesney, pers. comm.). 

Historically, there may have been well over a million (Carter et al. 2001). Due to 

favorable oceanic conditions in recent years, the central California population has begun 

to recover and has grown at an average rate of over 5% per year (from 1990 to 2004 at 

the Farallon Islands). In good years, the population grows as much as 7-9% per year. In 

bad years, a fraction of the population attends the breeding colonies. Recovery to 

historical levels has been impacted and delayed by the spills. Nur et al. (1997) estimated 

that chronic oil pollution (now largely attributed to the Luckenbach) may have lowered 

population growth rates by as much as 3% per year. The modeling here, using the 

mortality estimates described in Appendix B, show an average annual reduction in 

population growth rates of under 1% per year for the entire population between 1990 and 

2003, although growth rates likely varied between colonies and certain colonies may 

have been more impacted from oil spill loss. 

The Trustees scaled restoration based upon a local population model that incorporated 

both “good years” (occurring 80% of the time) and “bad years” (20% of time). The 

model is based on the assumptions that, while no density dependent mechanism is 

currently operating in the population, reproductive output at high population levels is 

ultimately affected by: (1) an absolute limitation of the number of birds that breed in the 

region; (2) potential variability in nest sites both within and across colonies; and (3) 

possible food source limitations around the breeding areas (i.e., that might results in 

longer, more energetically intensive, food searches during breeding season). The 

underlying population model is similar to the approach used by Swartzman (1996) in his 

analysis of impacts to the Common Murre from the Apex Houston oil spill.1

 

Common Murre demographics were derived based on a various sources (Nur et al. 1994; 

Swartzman 1996; Carter et al. 2001; W. Sydeman, pers. com). The model was calibrated 

using historical breeding population estimates, estimated mortality from the various spill 

years, known oceanic conditions from the past (i.e., “good years” and “bad years”). The 

following set of demographic parameters reflects that calibration: 

 Female Offspring per Female in Pop. (Age 7+): 0.40 (good year); 0.04 (bad 

year) 

 Female Offspring per Female in Pop. (Age 6): 90% of fully mature (age 7+) 

 

1

 The multiple breeding rocks within the spill area suggest the possibility that a “meta-population” model 

might better reflect the response to both the mortality events and restoration projects. We mostly focus on a 

single population model because: (1) we have insufficient information to specify immigration-emmigration 

parameters between colonies inside the spill area; (2) the majority of birds are in a single colony (South 

Farallon Island complex) and the dominant portion of birds is in two closely proximate colonies (South and 

North Farallon Island complexes). 
 I-2 

 Female Offspring per Female in Pop. (Age 5): 60% of fully mature (age 7+) 

 Female Offspring per Female in Pop. (Age 4): 35% of fully mature (age 7+) 

 Proportion of Females Breeding (Age 4): 48% (good year); 15% (bad year) 

 Proportion of Females Breeding (Age 5): 71% (good year); 23% (bad year) 

 Proportion of Females Breeding (Age 6+): 95% (good year); 30% (bad year) 

 Survivorship (From fledge to one year of age): 60% (good year); 30% (bad 

year) 

 Annual Survivorship (Age 1-2): 83% (good year); 80% (bad year) 

 Annual Survivorship (Age 2-3): 90% (good year); 87% (bad year) 

 Annual Survivorship (Age 3+): 96% (good year); 92% (bad year) 

For future losses and gains, the Trustees used “average conditions” to examine the 

population. Average was based upon the proportion-weighted geometric means of 

parameters from both good- and bad-years.2

 When approximating future population 

growth, the Trustees assume that there is a maximum of 1,000,000 breeding birds (per 

Carter et al. 2001), that density dependence will begin to operate at 50% of this 

maximum, and that mature fledging success will decline linearly with breeding 

population size until it reaches the stationary value when there are 1,000,000 breeding 

birds in the population. 

Figure 1 plots the combined good-year and bad-year growth rates against estimates of 

breeding birds based upon historic colony counts. The error bars around the estimates are 

10% to reflect the 8-12% error in using a constant correction factor (k = 1.6) to transform 

colony counts to breeding population size (Nur and Sydeman 2002). 1992 and 1998 are 

assumed to be “bad years” because of the 1992-93 and 1998-99 El Nino events. The solid 

line is the estimated trajectory that includes spill mortality. The model underestimates the 

2002 and 2003 colony counts, which is reasonable as the 2002 and 2003 counts may 

include an uncharacteristically large number of non-breeding sub-adults that are a result 

of several sequential productive years (W. Sydeman, pers. comm.). The dashed line is the 

predicted population trajectory assuming that the estimated spill mortality did not occur. 

The injury is the area between the solid and dashed lines. 

 

2

 A stochastic population model was compared with the “average population” model to ensure consistency 

of the deterministic approximation. 
 I-3 

Spill mortality is described in the table below: 

Spill Event

Estimated 

Mortality 

Winter 1990-91 2,348 

Winter 1992-93 47 

Chronic 1993-1997 37 

Winter 1997-98 23,152 

Winter 2001-02 5,091 

Winter 2002-03 1,068 

Chronic 1998-2001 63 

TOTAL 31,806 

0

50,000

100,000

150,000

200,000

250,000

300,000

1988 1990 1992 1994 1996 1998 2000 2002 2004

Year 

Number of Birds 

Figure 1: Calibrated population trajectories and breeding bird estimates from colony 

counts 

With Spill 

Without Spill
 I-4 

CREDIT CALCULATION (projected restoration benefits) 

To address the injuries, the Trustees are proposing three restoration projects: 1) regional 

colony protection, 2) corvid management at Pt. Reyes, and 3) Reading Rock colony 

restoration. 

1. Colony Protection 

The seabird colony protection project, which seeks to reduce human disturbances at 

nesting colonies throughout the region, was examined as the same time as the injury 

using the same population model. This project will add to and extend an on-going project 

being implemented by the Command Trustee Council. Three population trajectories were 

examined: 

• Baseline: a projection of the number of Common Murres in the spill area, 

including benefits of the initial colony protection program implemented by the 

Command Trustees (which increases nest success for the years 2006 to 2009). 

• Injury: a projection of the number of murres in the central California population 

that incorporates both the spill mortality from the Luckenbach (and other local 

orphan spills) and the colony protection project implemented by the Command 

Trustees. 

• Restoration: a projection of the number of murres in the central California 

population, given: (1) the various spill events; (2) colony protection from the 

Command Trustees; and (3) colony protection funded from a project that begins 

providing benefits to Common Murres in 2010 (once the Command project 

ceases). 

Figure 2 illustrates the spill injuries and colony protection benefits using the trajectories. 

The injury depicted in Figure 2 is the difference between the Baseline and Injury 

trajectory (i.e., “How much did the public lose compared to Baseline?”). The restoration 

credit is the difference between the Restoration and Injury trajectories (i.e., “How much 

does the public gain now that the restoration project benefits the injured population?”). 

The modeling showed that a 20-year seabird colony protection project, which increases 

fecundity by 5%, compensates for approximately 38% of the spill injuries (in discounted 

bird-years). 
 I-5 

2. Corvid Management 

The project is based upon the observation that nest predation by corvids has resulted in 

lower nest success at Pt. Reyes than the overall average in the spill area (Parker et al. 

2000, Parker et al.2001, Knectel et al.2003). Since the corvid management option will 

only benefit the Pt. Reyes colony, we focus on increases in productivity at that site. The 

benefits are based upon the comparison of two population trajectories: 

• Baseline (without restoration): Pt. Reyes Headlands murre population size over 

time given post-spill colony numbers and the positive impacts of the human 

disturbance colony protection project noted above. 

• Restoration: This is the baseline condition with the increased nest success at Pt. 

Reyes Headlands that results from reducing corvid predation. 

The gain from the corvid management project is the difference between these two 

trajectories. 

Average nest success (i.e., fledges per nest) at study plots in the Pt. Reyes colony was 

approximately 81% of the nest success at plots at the Farallones over the 1999-2002 

period (Parker et al.2000, Parker et al.2001, Knectel et al.2003, Worzybok et al.2003). 

For the purpose of quantifying restoration benefits, the Trustees assume that the 

-80,000

-60,000

-40,000

-20,000

0

20,000

40,000

60,000

80,000

1990 2010 2030 2050 2070 2090

Year 

Net-Gain in # of Birds 

Figure 2: Luckenbach spill injury/debit of COMU and restoration gains from 

colony protection 

Spill 

Injury/Debit 

Colony 

Protection

Credits 
 I-6 

“baseline” nests at Pt. Reyes are 81% as successful as the current area-wide average. This 

nest success assumption calibrated to past changes in colony counts. The Trustees also 

assumed that the nests will be 90% successful as the area-wide average after the corvid 

management program is implemented. The Trustees do not credit the project with 

achieving a full 100% of the Farallones nest success because: (1) corvid management 

may not be 100% successful; and (2) other factors may also be contributing to a reduced 

nest success at the Pt. Reyes colony. 

The underlying population model used to calculate corvid management benefits is similar 

to the one used to model the entire spill injury and colony protection benefits. The 

Trustees use the same density dependent mechanisms and same survivorship parameters. 

However, a limit of 100,000 birds is used instead of one million breeding birds, and the 

project is assumed to provide benefits for 100 years. This long duration assumes that 

PRNS will continue to manage its corvid populations. Figure 3 depicts the trajectories 

with and without the restoration project. The difference between them is the net-gain 

from this project, which compensates for approximately 21% of the injury. 

(3) Reading Rock Colony Restoration 

Calculation of the restoration benefits of the Reading Rock murre colony restoration 

project is based upon the assumption that social attraction at Reading Rock would draw 

“not otherwise breeding” adults associated with other colonies in the region. The rate at 

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

160,000

180,000

200,000

1990 2040 2090 2140 2190

Year 

Number of Birds in Colony (all ages) 

Figure 3: Restoration gains from corvid management at the Pt. Reyes 

colony 

Corvid 

Management 

Credits 

With Restoration 

Without Restoration 
 I-7 

which social attraction resulted in new nests was quantified using data from recent 

restoration efforts at the Devil’s Slide Rock, and assuming a 5% growth rate in nests 

beyond the available data (until a maximum of 1,800 nests are achieved). This is 

summarized in the following table: 

Year

Increased 

Nests 

Increased 

Fledges 

Increased 

Bird-Years 

Discounted 

to 2006 

2008 0 0 0 0

2009 6 4 17 16 

2010 9 6 26 23 

2011 14 10 40 34 

2012 70 51 199 167 

2013 98 71 279 227 

2014 115 83 327 258 

2015 123 89 350 268 

2016 109 79 310 231 

2017 190 137 540 390 

Continues 

to 2107 

Continues at 

5% annual 

growth until 

maximum at 

1,800 nests. 

Based on 

0.722 

fledges per 

nest. 

Based on 

3.94 birdyears per 

fledge (life 

expectancy 

of a fledge) 

Discounted 

at 3% per 

year 

Total: 53,772 

Note: First seven years of nest numbers and fledges per nest based on 

data from Devil’s Slide Rock Murre Re-colonization Project 

(McChesney et al.2004).

Estimates of gained bird-years per fledge are based upon demographic parameters that 

were calibrated to the roughly constant Common Murre population levels off the North 

Coast. A more detailed description of these parameters (and the scaling) can be found in 

Stuyvesant Trustee Council (2004). 

Other funding sources are expected to contribute 81% of the funding to conduct the 

Reading Rock project. This leaves a 19% contribution available for funding via the 

Luckenbach claim. A project that contributes 19% of the funding would account for 19% 

of the gained bird-years (i.e., 10,217 bird-years discounted to 2006). 

Summary of Common Murre Project Scaling 

Altogether, these three projects address approximately 61% of the injury to Common 

Murres. Due to the size of the injury and the fact that several other projects benefiting 

Common Murres (associated with other oil spills) are already being implemented (e.g. 

see Command Trustee Council (2004), Stuyvesant Trustee Council (2004), and 

McChesney et al.(2005)), the Trustees have not identified any additional projects at this 

time. 
 J-1 

Appendix J: Marbled Murrelet REA Details

INJURY CALCULATION

The Trustees calculated the injury to Marbled Murrelets using a species-specific model 

incorporating data from the declining Santa Cruz Mountain population. First, the 

Trustees modeled both baseline and injured trajectories of the population. The injured 

trajectory started with the same initial population level as the baseline trajectory, but the 

birds were removed consistent with estimated spill mortality. 

Spill Event

Estimated 

Mortality 

winter 1990-91 4 

chronic 1993-97 0 

winter 1997-98 32 

chronic 1998-2001 0 

2001-2003 9 

TOTAL 45 

Both population trajectories relied on the following adaptation of the Beissinger (1995) 

model. 

 

The parameters s0, s1, and s2 are the survivorships for juveniles, subadults and adults, 

respectively. The term s2F(n2) reflects the “post-breeding” census convention (i.e., birdyears are counted in the fall). This implies that adult murrelets (n2) must survive (s2) 

before they are able to attempt successful breeding (F(n2)). In the model, fecundity 

increases as the population becomes smaller. This reflects the possibility that, as a 

population declines, it will tend to decline faster in more marginal areas leaving the 

remaining birds in higher quality habitat. The estimate of lost bird-years is the difference 

between the two trajectories. The parameters are presented below. 

CREDIT CALCULATION (projected restoration benefits) 

The Trustees are proposing two restoration projects to address the injury to Marbled 

Murrelets. Land acquisition would protect nests that would otherwise be subject to total 

loss through logging. The corvid management project in Santa Cruz Mountain 

2 

Adults 

1 

Subadults

0 

Juveniles 

s0 s1

s2

s2F(n2)
 J-2 

campgrounds would increase nest success by decreasing the predation of eggs and chicks 

by corvids. At present, nest success in the Santa Cruz Mountains is extremely low. 

There is sufficient data regarding murrelet reproduction to scale the land acquisition 

project. Unfortunately, because murrelet nests are so difficult to monitor, there is little 

data regarding changes in nest success as a result of corvid management. The Trustees 

have conducted the scaling based upon the land acquisition project, assuming that, 

because it will be concurrent with the corvid management project, the nests to be 

protected by land acquisition will be “good nests” (i.e. they will produce enough 

fledglings to stabilize the population level and stop further declines). Thus, the 

implementation of the corvid management project justifies this critical assumption 

regarding nest success in the lands to be protected. 

The land acquisition project is scaled based upon the number of good nests that must be 

protected in order to offset the injury. The number of acres that must be acquired is 

simply a function of average nest density. The benefit per protected nest is the difference 

between fecundity at the protected site (without logging) and what fecundity would be if 

the birds were forced to nest elsewhere (with logging). Because the corvid management 

project will be implemented simultaneously, we assume that: (a) with acquisition, nests 

are sufficiently productive to maintain population levels; and (b) without acquisition, the 

birds associated with these nests will reproduce at a lower fecundity after logging occurs. 

The model was calibrated using population estimates (see McShane et al.2004), estimated 

mortality from the various spill years, and estimates of Marbled Murrelet demographic 

parameters (Beissinger 1995, Cam et al.2003, McShane et al.2004, Nur 1993). Because 

there is uncertainty with regard to several of the parameters, the Trustees conducted a 

Monte Carlo analysis that examined ranges of parameter inputs, subject to constraints for 

biological consistency (e.g., was consistent with “juvenile ratio” observations at-sea). 

2,000 combinations of parameter inputs were explored. The potential parameter ranges 

for the main inputs were: 

 Annual Survivorship (Age 2+): 83-93% 

 Annual Survivorship (Age 1-2): 83-95% of Age 2+ Survivorship 

 Survivorship (From fledge to one year of age): 60-82% of Age 2+ Survivorship

 Female Offspring per Female (Annual): Selected to be consistent with 5-10% 

annual population decline, given survivorship

 Logging Time: Between October 2010 and March 2011 

Eliminating the first and last quartiles from the simulation results, the Monte Carlo 

analysis suggests that protecting 5.7 to 7.7 nests would compensate for the injury. Using 

an average of 20 acres per nest (Conroy et al.2002), 114 to 154 acres would need to be 

protected from logging.
 K-1 

Appendix K: Ancient Murrelet/Queen Charlotte Islands REA Details 

INJURY CALCULATION

Because breeding populations of the Ancient Murrelet may be limited by suitable nest 

colony sites (Gaston 1994), the Trustees applied the single-generation stepwise 

replacement approach to calculating lost bird-years as described in Appendix C. A lost 

bird-year multiplier (i.e. lost bird-years per bird killed) is first calculated, and then 

applied to the mortality events from the various years, discounted to 2006. 

The following set of demographic parameters implies an approximately constant 

population size: 

 Age of First Breeding: 3 Year Old 

 Female Offspring per Female (Annual): 0.825 

 Survivorship (From fledge to one year of age): 59% 

 Annual Survivorship (Age 1-2): 62% 

 Survivorship (Age 1+): 77% 

 Maximum Age: 20 Years Old 

These parameters are consistent with data from information summarized in Gaston 

(1994). The result is that the bird-year multiplier is 3.48. 

This multiplier is then applied to the various mortality events, discounted to 2006. 

Spill Event

Estimated 

Mortality 

Discounted Lost 

Bird-Years 

winter 1990-91 42 228 

chronic 1993-97 0 0 

winter 1997-98 281 1,240 

chronic 1998-2001 0 0 

2001-2003 105 400 

TOTAL 428 1,867 

Total discounted lost bird-years for Ancient Murrelets: 1,867. 

CREDIT CALCULATION (projected restoration benefits) 

For project scaling, the Trustees focused on potential benefits from rat eradication at 

Ellen Island and the Bischof Islands. Full compensation for the injury can be achieved if 

re-colonization from adjacent islands occurs at a rate of just 2 nests per year, beginning in 

the year 2010 and continuing through 2100. This calculation also assumes a 1% annual 

risk of rat reintroduction for the first 10 years, increasing by 1% in each of the following 

decades. This effectively incorporates uncertainty into the discount rate. The risk of 

rodent reintroduction is greater here than on the Farallones because the islands are 

difficult to monitor. The Farallones, in contrast, have full-time research staff and every 

boat landing can be monitored. Benefits per nest were assumed to be 1.65 fledges/nest, at 

the high end of the range reported by Gaston (1994). The table below presents these 

results. 
 K-2 

Year

New 

Nests 

New 

Fledges 

New 

Bird-Years 

Discounted 

to 2006 

2007 0 0 0 0 

2008 0 0 0 0 

2009 0 0 0 0 

2010 2 3 10 8 

2011 4 7 19 16 

2012 6 10 29 23 

2013 8 13 39 29 

2014 10 17 48 35 

2015 12 20 58 41 

2016 14 23 68 46 

2017 16 26 77 50 

2018 18 30 87 54 

2019 20 33 97 51 

2020 22 36 106 54 

2021 24 40 116 56 

2022 26 43 126 58 

2023 28 46 136 59 

2024 30 50 145 60 

2025 32 53 155 61 

2026 34 56 165 62 

2027 36 59 174 63 

2028 38 63 184 63 

2029 40 66 194 51 

2030 42 69 203 50 

Increases at 

2 nests per 

year, 

continuing 

thru 2100. 

Based on 

1.65 fledges 

per nest. 

Based on 

2.93 birdyears per 

fledge (life 

expectancy 

of a fledge) 

Discounted 

at 3% per 

year 

Total: 1,813 

The Trustees believe that these assumptions can be met. If so, this project compensates 

for the lost bird-years. 
 L-1 

Appendix L: Rhinoceros Auklet/Año Nuevo Island REA Details 

INJURY CALCULATION

For Rhinoceros Auklets, the Trustees applied the single-generation stepwise replacement 

approach because breeding populations appear limited by suitable nest sites (Gaston and 

Dechense 1996). A lost bird-year multiplier (i.e. lost bird-years per bird killed) is first 

calculated, and then applied to the mortality events from the various years, discounted to 

2006. 

Thayer et al.(in prep) estimated age of first breeding, annual productivity, and adult 

annual survival at Año Nuevo Island and Southeast Farallon Island. The Trustees relied 

upon this data and estimates from other alcids, calibrating the parameters subject to the 

constraint that the population be constant. 

Rhinoceros Auklet

 Age of First Breeding: 4 Years Old 

 Female Offspring per Female: 0.325 

 Annual Survivorship (Age 1-2+): 85% 

 Survivorship (From fledge to one year of age): 75% 

 Maximum Age: 30 Years 

The result is that the bird-year multiplier for Rhinoceros Auklets is 5.52. 

This multiplier is then applied to the various mortality events, discounted to 2006. 

Spill Event

Estimated 

Mortality 

Discounted Lost 

Bird-Years 

winter 1990-91 59 507 

chronic 1993-97 1 8 

winter 1997-98 379 2,650 

chronic 1998-2001 5 32 

2001-2003 149 899 

TOTAL 593 4,095 

Total discounted lost bird-years for Rhinoceros Auklets: 4,095 

CREDIT CALCULATION (projected restoration benefits) 

These injuries will be addressed by restoration efforts at Año Nuevo Island. The 

restoration work on Año Nuevo is expected to increase the number of nests on the island. 

Without the project, the auklet colony would likely decline rapidly due to soil erosion. 

Thus, the restoration benefits derive from the difference between modest colony growth 

with the project and total loss of the colony without the project.

For scaling purposes, without the project, the number of nests on the island falls from its 

current level of 106 to zero over 21 years (losing 5 nests per year). With the project, the 

colony is maintained and the number of nests increases at 2% per year, from 106 to 134 

at the end of the project life. Once the project ceases, there is considerable uncertainty 

about the persistence of the colony. If the native vegetation cover is not firmly 
 L-2 

established, erosion processes may repeat. The Trustees have accounted for uncertainty 

after the life of the project by assuming a decrease in the number of nests at a rate of 5 

nests per year. Thus, the project is assumed to provide some level of benefits through 

2045. The table below presents these results. 

 

Year

Nests w/o 

Project 

Nests w/ 

Project 

Gained 

Nests 

Gained 

Fledges 

Gained 

Bird-Years 

Discounted

to 2006 

2007 106 106 0 0 0 0 

2008 100 108 8 5 27 26 

2009 95 110 15 10 51 48 

2010 90 112 22 15 75 69 

2011 85 115 30 19 100 89 

2012 80 117 37 24 124 107 

2013 75 119 44 29 149 124 

2014 70 122 52 34 173 141 

2015 65 124 59 38 198 157 

2016 60 127 67 43 223 171 

2017 55 129 74 48 249 185 

2018 50 132 82 53 274 198 

2019 45 134 89 58 300 210 

2020 40 129 89 58 300 204 

2021 35 124 89 58 300 198 

2022 30 119 89 58 300 192 

2023 25 114 89 58 300 187 

2024 20 109 89 58 300 181 

2025 15 104 89 58 300 176 

2026 10 99 89 58 300 171 

2027 5 94 89 58 300 166 

2028 0 89 89 58 300 161 

2029 0 84 84 55 283 148 

2030 0 79 79 52 266 135 

 Continues to 

lose 5 nests 

per year; 

reaches 0 in 

2045. 

Continues 

thru 2045. 

Based on 

0.65 fledges 

per nest. 

Based on 

5.15 birdyears per 

fledge (life 

expectancy 

of a fledge) 

Discounted 

at 3% per 

year 

Total: 4,299 

Under these assumptions, this project compensates for the lost bird-years. 
 M-1 

Appendix M: Sea Otter/Public Education REA Details 

INJURY CALCULATION

Because the otters saved by the restoration action are assumed to be from the same 

demographic age classes as those impacted by the spills (and thus have the same 

contribution to future population size), calculating lost otter-years is not necessary. 

Instead, the Trustees simply counted lost and gained otters, discounted to 2006. 

The Trustees estimate that eight sea otters were killed by mystery spills between 1995 

and 2002. 

Spill Event 

Estimated 

Mortality Discounted Otter Loss 

winter 1995-96 2 2.77 

winter 1998-99 2 2.53 

winter 2001-02 4 4.64 

TOTAL 8 9.9 

The total loss is 9.9 sea otters, discounted to 2006. 

CREDIT CALCULATION (projected restoration benefits) 

The injuries will be addressed by a public education project intended to reduce the 

mortality of sea otters that results from certain human actions. Quantifying the decreased 

level of pollution and the resulting increased survival of sea otters from a public 

education project involves considerable uncertainty. To evaluate the potential of the 

project to achieve the necessary compensation, the Trustees instead asked how many 

otters must be “saved” by the project in order to offset the injury, and whether or not this 

level of decreased otter mortality was likely to be achieved by the project. 

If the project saves two sea otters per year over a six-year period, a total of 10.8 

“discounted” otters would be saved, thus compensating for the injury. 

Year Otters Saved Discounted Otter Gain 

winter 2007-08 2 1.94 

winter 2008-09 2 1.89 

winter 2009-10 2 1.83 

winter 2010-11 2 1.78 

winter 2011-12 2 1.73 

winter 2012-13 2 1.67 

TOTAL 12 10.8 

Based on Gerber et al.(2004), approximately 325 sea otters die each year. 59 of these 

(18%), and possibly as many as 156 (48%), die from diseases, some of which will be 

addressed by the project. If the project can reduce this mortality just 4%, the goal of 

saving two otters per year will be achieved. The Trustees believe this is possible. 
 N-1 

Appendix N: Summary of Public Comments and Trustee Replies 

This appendix summarizes the written and verbal public comments by topic and provides 

the response of the Trustees to each issue. A copy of the written public comments is 

provided in Appendix O. 

Restoration Priorities 

One commenter noted that the Luckenbach Trustee Council should prioritize restoration 

for rare species (i.e. those with limited ranges and smaller population sizes) over more 

common species. Another comment encouraged the Trustees to preferentially select 

restoration projects that have the greatest lasting benefits for affected populations, which 

focus on the most significant driving factors regarding population change or ecosystem 

function, and to give priority to projects that benefit multiple species. 

Trustee Reply: 

The first comment highlights an important difference between general resource 

agency goals and the specific natural resource damage assessment and restoration 

process. Resource agencies are often concerned with rare and endangered species 

and devote significant efforts toward these species. Acting as trustees for injured 

natural resources under OPA, the same resource agencies may seek restoration only 

for the resources injured in an oil spill. In most spill scenarios, it is the common 

species that are impacted in the greatest numbers. Using restoration scaling 

guidelines (which focus on lost and gained bird-years), compensatory projects for 

these common species are often quite large. Restoration projects for rare species may 

be significant as well, as greater effort (and expense) is often required to restore their 

fragile populations. 

In either case, it is our goal under OPA to achieve the appropriate amounts of 

compensation for all injured resources, whether common or rare. Because of our 

concern for rare species, we are especially careful to ensure that their injuries are 

directly addressed. For example, in this case, because over 50 bird species were 

impacted, we have combined many of the more common species into family groups 

and proposed a single restoration project that addresses the group as a whole, 

although only one or two species from the group are acting as a surrogate and directly 

benefit from the project. In the case of rare species, we were careful to ensure that 

they will directly benefit from restoration actions. In this case, the rare species that 

we are most concerned about are the Ashy Storm-Petrel, Snowy Plover, Marbled 

Murrelet, and California Sea Otter. Many of the other species also have important 

conservation needs and their populations are either depressed from historic levels or 

are currently declining. We have attempted to address their needs to the extent 

possible. 

Regarding the second comment on restoration criteria, we concur. A full list of the 

criteria we used to evaluate proposed projects is in section 4.2.2 of the DARP. At the 

same time, cost efficiency is an important consideration when choosing among 

projects. It was because of these criteria that we proposed some projects on breeding 
 N-2 

grounds far away from the spill site (e.g. Alaska, Canada, Mexico), as we believe 

these projects addressed biological bottlenecks in the most efficient manner and, in 

many instances, provided benefits to multiple species. 

Expert Review of the Projects 

One commenter expressed concerns that it is unreasonable to expect many detailed public 

comments on such a large document. The commenter proposed that the Trustees contract 

with selected experts to provide a detailed review of the proposed projects. 

Trustee Reply: 

The Draft DARP was subjected to a detailed review by selected experts prior to its 

release. Specifically, the injury quantification, restoration project description, and 

restoration project scaling sections (in the Appendices) for each species group were 

reviewed by some of the most well-known experts in seabird restoration in North 

America. A list of all of the experts consulted during the injury assessment and 

restoration planning is provided in Section 7.0. 

Additionally, we received public comments from several of the foremost seabird 

ornithologists on the West Coast, as well as from several organizations known for 

their scientific credentials (e.g. Pacific Seabird Group, Seymour Center at the Long 

Marine Lab). Public comments often range from expert to layman in nature. We are 

satisfied with the scope, quality, and quantity of public comments received and value 

all comments received. The Draft DARP is also an Environmental Assessment 

pursuant to the National Environmental Policy Act (NEPA). A fundamental purpose 

of NEPA is to ensure an opportunity for public involvement in federal decision or 

actions that may affect the quality of the human environment. 

Monitoring 

One commenter stressed the importance of monitoring the changes attributed to the 

projects. They pointed out that it is important to demonstrate the effects of projects as 

well as providing baseline information for future assessments. 

Trustee Reply: 

All of the projects include a monitoring component, as is provided under OPA 

regulations. While the primary intent of our monitoring is to document the success or 

failure of the project, the data collected may be suitable for baseline information in 

the event of a future spill. 

Outreach/Education 

One commenter recommended that some restoration funds go toward supporting 

educational facilities and outreach at state parks listed in the DARP in addition to 

educational materials described for some of the projects. 

Trustee Reply: 

We recognize the importance of outreach and education as a means of engaging the 

public in restoration in general and in the Luckenbach case in particular. Many of the 
 N-3 

restoration actions that we have selected will include an outreach and education 

element, typically targeted at a particular user-group (e.g., pilots, boaters, etc.). If 

there is opportunity to include state parks in these activities, we will do so. 

Process 

One commenter questioned the process by which pre-planning funding was allocated. 

For example, they noted that some contracts, such as funding the scoping of certain 

projects, were not made available to the general public, such as in a request for proposals 

format. The commenter expressed concern that those projects developed for the Draft 

DARP may be “favored” over projects suggested after the document has been put out for 

public review.

Trustee Reply: 

In conducting natural resource damage assessments, restoration planning, and 

restoration project implementation, we rely on both government agency resources and 

the private sector. When relying on contractors from the private sector, it is our intent 

to use open competitive bidding whenever possible. There are some special 

circumstances when we may elect to use a non-competitive process (i.e. “sole 

source”) when selecting a contractor. Because seabird restoration is a highly 

specialized field with relatively few experts, we have elected to use certain 

contractors in a non-competitive process in certain situations. For example, when 

focusing on projects in foreign countries (e.g., New Zealand, Mexico, Canada), 

especially when indigenous peoples are involved, we have sometimes selected 

contractors that had a previously established relationship with the governing 

authorities and peoples of these regions. We feel this has ensured the greater caution 

and sensitivity required to implement these projects. 

We subject all potential projects to the same screening criteria, whether they are 

identified by a government agency, someone under contract to a Trustee, or a member 

of the general public. In several recent instances, the trustees have added new 

projects to the Final DARP that were suggested during the public comment period. 

Recent examples are two projects to restore Sooty Shearwaters, one in this Final 

DARP and one by the Command Trustee Council. 

Overall Support for the Restoration Plan 

We received many supportive comments related to the restoration projects outlined in the 

draft plan. We appreciate these comments and, like all comments received, weighed 

them as part of our decision-making process when developing the final plan. These 

comments are summarized below: 

• Several comments were received commending the Trustees for their 

forward-thinking approach to developing restoration projects in Mexico, 

Canada, and inland regions where much conservation value can be gained 

for the diverse migratory species affected by the chronic oiling off the 

California coast. 

 
 N-4 

• One commenter expressed support of the corvid management projects at 

Point Reyes and Santa Cruz Mountains and pointed out that addressing 

habitat factors for Snowy Plovers and murrelets is valuable for these 

species as well. 

• Several commenters appreciated the diversity and complexity of issues 

addressed in the draft plan. 

• One commenter expressed support for the projects on Baja California 

islands, stating that protection and outreach/education at these breeding 

colonies provide unparalleled opportunity for effective and economical 

conservation of seabirds. 

• One comment expressed support for the eradication projects identified in 

the plan. The commenter expressed that in their opinion, one of the most 

effective restoration actions for seabirds, seabird communities, and island 

ecosystems in general, is to remove non-native invasive species that 

significantly alter island ecosystems. 

• Many comments where received in support of the Sea Otters Pathogens 

Education and Outreach Project and of the benefits it will provide to the 

public that visit the Seymour Center in large numbers. 

• A letter of support was received from Parks Canada –Gwaii Haanas 

National Park Reserve and Haida Heritage Site, regarding the rat 

eradication project in the Queen Charlotte Islands that will occur within 

that preserve. The letter voiced support for the project and stated that it 

was consistent with the Reserve’s goal of restoring ecological integrity to 

the Gwaii Haanas preserve. 

Procellarid Restoration 

Several people commented that restoration for Procellarids was not addressed for several 

important species, most notably Laysan Albatross, Northern Fulmar, and Black-vented, 

Pink-footed, and Sooty Shearwater. These species were either injured in the spills or 

were likely injured, albeit in small numbers. The trustees placed all of these species into 

the Procellarid group for restoration purposes, and proposed to address their injuries via 

the Farallon Island mouse eradication project, which will only directly benefit Ashy 

Storm-Petrels. While one commenter expressed support for the Ashy Storm-Petrel 

project on the Farallones, they pointed out that this project will not benefit the other 

Procellarid species within this restoration category. The commenter suggested that 

restoration for other Procellarids would most effectively be accomplished by addressing 

conservation issues in other regions (e.g., New Zealand, Chile, Alaska, Mexico) in 

addition to the Farallones. Ideas included Arctic Ground-Squirrel eradication on the 

Semidi Islands, Alaska to benefit Northern Fulmars and other species (for which a 

detailed project description was provided); various projects in Chile and New Zealand to 
 N-5 

benefit Pink-footed and Sooty Shearwaters, respectively; and actions to benefit Blackvented Shearwaters in Baja California, Mexico. 

Trustee Reply: 

The Trustees acknowledge that, under the Draft DARP, Ashy Storm-Petrels would be 

the only Procellarid to directly benefit from restoration actions. They are, however, 

among the most threatened and nest in closest proximity to the spill, with nearly half 

of their remaining population breeding on the Farallon Islands. 

We have decided to add a project in the Final DARP. This project was proposed 

during the public comment period and addresses restoration for other Procellarid 

species. The project will protect the largest remaining Sooty Shearwater colony on 

mainland New Zealand from disturbance and depredation by non-native mammals. It 

is described in Section 4.3.4. 

We also investigated a potential restoration project for Northern Fulmars and other 

species at the Semidi Islands in Alaska. This project would eradicate Arctic GroundSquirrels from one to five islands as a way to increase nest productivity. While this 

project may have merit, it is not yet ready for inclusion in this restoration plan. First 

of all, it has yet to be determined if the ground-squirrels are native or introduced. 

They would only be eradicated if they are determined to be non-native and 

introduced. Second, while there is anecdotal evidence of ground-squirrel depredation 

on Rhinoceros Auklet nests and circumstantial evidence of impacts to storm-petrels 

and some small alcids, there is currently little information on the impacts of predation 

and little evidence of impacts to Northern Fulmars specifically. To resolve these 

unknowns, funding and time for study are needed. The trustees prefer projects that 

are presently known to be feasible and have a high likelihood of providing 

measurable benefits. The Semidi Islands project does not yet meet these criteria. For 

these reasons, we have not included the project in the Final DARP. 

With regard to Laysan Albatross, Black-vented Shearwater, and Pink-footed 

Shearwater, only four individuals of these species were recovered (one Pink-footed 

and three Black-vented). Black-vented Shearwaters will experience ancillary benefits 

from restoration actions at Natividad Island in Baja California, Mexico. Because of 

these factors, we feel additional species-specific restoration actions for these species 

are not warranted. 

Mouse Eradication at the Farallon Islands 

One commenter expressed concerns regarding the Mouse Eradication Project on the 

Farallon Islands. They claimed that: (1) the direct impact of mouse predation on Farallon 

Ashy Storm-petrels is not well substantiated; (2) the project does not address the problem 

of gull predation and mouse eradication will not restore the Ashy Storm-petrel population 

unless combined with gull control; and (3) habitat restoration, by using concrete slabs or 

artificial nesting boxes to create suitable nesting areas without gulls, would be a relatively 

low-cost solution to use in combination with mouse eradication and gull control. 
 N-6 

Trustee Reply: 

We discussed these issues with the Farallon Islands NWR. While there is some 

documented and anecdotal evidence that house mice eat storm-petrel chicks or eggs, 

the most significant impact is indirect mortality to the adult storm-petrel breeding 

population, through owl predation, as described in the restoration plan. The owls’ 

diet shift from mice to petrels in the breeding season has been well-documented 

through the systematic collection of owl pellets on Southeast Farallon Island since 

2000. Even though only a small number (3-5) of owls over-winter, they kill a 

considerable number of petrels each year. 70% of the owl pellets analyzed during the 

early spring contained petrel remains. These are almost certainly breeding birds that 

arrive on the island to establish nesting sites. Such high adult mortality of a longlived, slow-reproducing seabird is of concern to population viability. 

The mouse eradication project is just one of several ongoing or planned actions being 

undertaken by the Farallon Islands NWR to reverse the petrel decline. Night lighting 

has been eliminated around and emanating from the buildings, reducing gull 

predation in lighted areas. The NWR has also tried to exclude nesting gulls from 

suitable petrel areas by erecting gull barriers (horizontal cables), but gulls began renesting in the areas after a very short time. Limited gull control of problem (i.e., 

petrel-eating) individuals is a proposed management action in the Comprehensive 

Conservation Plan (CCP), currently being prepared by the USFWS. The NWR has 

used ultra low-light video cameras in an attempt to pinpoint petrel-eating gull 

specialists. The NWR is also trying to better quantify the relative impact of gull and 

owl predation on petrels by a more thorough analysis of petrel remains and owl 

pellets. During the 1980s and 90s, it was assumed that all petrel wings (remains) 

found or collected were killed by gulls. Only recently (since the late 1990s) have 

burrowing owls been found to be a larger mortality factor than previously thought. 

Systematic collection of petrel wings began in 2000, and these are being more 

thoroughly examined and analyzed to determine the role each predator plays. 

Over the past ten years the NWR has unsuccessfully implemented a number of habitat 

restoration projects to benefit Ashy Storm-Petrels. Several concrete foundations were 

broken up and rocks stacked to create petrel-sized crevices. Bricks and other 

materials have also been used to create crevices. These were unsuccessful in 

attracting nesting petrels, so nesting boxes were added to the rock piles, and also 

placed in other areas around the island thought to lack natural crevices. When petrels 

still remained un-enticed, olfactory attractants (petrel feathers) and petrel sound 

recordings were used to better lure petrels to boxes and crevices. Unfortunately, all 

of these attempts have failed; although other crevice nesters such as auklets and 

Pigeon Guillemots have used some of the habitat. Western Gulls have expanded their 

nesting areas on Southeast Island Farallon to the point where there is virtually no 

suitable petrel habitat that is not in close proximity to nesting gulls. Even though 

habitat restoration has thus far been unsuccessful, the NWR continues to experiment 

with new ideas as funding permits. Solutions have not proven to be easy or low-cost. 
 N-7 

For these reasons, we have decided to continue with the Farallon mouse eradication 

project as planned and not to incorporate additional habitat alteration features. 

Seabird Colony Restoration at Baja California Islands Project 

One comment suggested that the proposed work at islands off Baja California, Mexico 

will not likely restore Cassin’s Auklets because their numbers have declined drastically 

due mainly to climate, oceanographic, and prey changes. However, long-term benefits 

may be attained by protecting vacant nesting habitat from human destruction. 

The commenter suggested that Cassin’s Auklets should instead be restored at the South 

Farallon Islands as a low-cost alternative. According to the commenter, predation 

reduction through habitat restoration (by providing predator-proof artificial habitat) and 

removing individual problem gulls and owls would have great benefits to this population 

and would only be a small extension of the Farallon Island Project. 

Several commenters expressed support of the project in Mexico for the benefits it will 

provide for the Xantus’s Murrelet and further recommended that this species become a 

target species for restoration actions and monitoring in the context of the Mexico project. 

The commenters suggested that this species was almost certainly killed by Luckenbach 

oilings based on timing and location of oiling events in relation to murrelet at-sea 

distribution. 

Trustee Reply: 

We anticipate restoration benefits for Cassin’s Auklets at all six of the Baja islands 

where work is proposed. The vast majority of the benefits will occur at San Benito 

Island, where a colony of 35,000 pairs should experience significant protection from 

the kinds of disturbances that can potentially destroy thousands of nests. We 

understand that all seabird populations are potentially subject to the vagaries of 

oceanographic conditions and prey availability. To account for this, we have used 

long-run average demographic parameters in estimating project benefits. This logic 

applies to all of the projects. Based upon our scaling, we anticipate that the Baja 

project will compensate for 205% of the Cassin’s Auklets estimated killed by the oil 

spills. While this is may imply over-compensation, the Baja project also addresses 

restoration for other species (e.g., pelicans, cormorants, gulls) and was thus deemed 

the most cost-effective way to restore these species. Cassin’s Auklets will also 

benefit in small ways (not quantified) from the Año Nuevo and Farallon Island 

projects. 

With regard to Xantus’s Murrelets, we agree that some individuals of this species 

may have been oiled in the spill events, even though none were collected. The public 

comments correctly note that this species will receive ancillary benefits in many ways 

from the Baja project. We believe that these ancillary benefits likely more than 

compensate for any injury that may have occurred to this species and thus have not 

proposed any additional restoration actions. With regard to monitoring, the 

monitoring for the Baja project may simultaneously collect data on Xantus’s 

Murrelets, although we will not direct specific monitoring toward this species. 
 N-8 

Seabird Colony Protection Project 

Several commenters stated that the Seabird Colony Protection Project creates little 

demonstrable population-level effects, seems excessive in its budget, and is too restricted 

in location for the amount of funds requested. 

Several commenters felt that the evaluation of the success of the project and true 

measurable benefits to target populations are hindered by our lack of understanding 

regarding what factors truly regulate these populations (i.e., juvenile, sub-adult, and adult 

survival, etc.). 

In addition, the commenters also felt that this project may be duplicating ongoing 

restoration efforts (e.g., of the Command Trustee Council) and should be funded under 

the mandate of a resource agency such as the USFWS or BLM. 

Finally, several people commented that the time for the project to provide benefits and 

feasibility seems low given that the Apex Houston-funded murre colony project has been 

documenting disturbance since 1995 and yet the problem continues. The comment 

suggested that the Trustees consider re-directing a great deal of the funds towards 

projects that have a greater conservation value. 

Trustee Reply: 

In general, we disagree with these assessments and present some information here to 

address these concerns. First, in developing this restoration project, we consulted 

with experts in seabird conservation. Through these consultations, we developed a 

list of threats to seabird populations in central California, with a strong focus on the 

Common Murre. Human disturbance to Common Murre nesting colonies was listed 

as one of the primary threats that are not being addressed by any coordinated 

conservation action. Additionally, significant disturbance events have been 

documented recently at most of the colonies targeted by this project (e.g., Hurricane 

Point/Castle Rock, Devil’s Slide Rock, Drake’s Bay, Point Reyes Headlands, and 

Farallon Islands). 

Common Murres were the species most heavily impacted by the Luckenbach releases, 

with an estimated total mortality of nearly 32,000 birds. The size and duration of this 

project was scaled to compensate for the size of the injury to the Common Murre. A 

total of 1,857,471 lost bird-years were calculated for the murre injury. These lost 

bird-years represent the interim losses between the time of the spills and the projected 

return of this population to pre-spill conditions. 

The size of the project (in area) was determined by both the human metropolitan 

region necessary to reach in order to educate boaters and pilots, and by the 

distribution of the Common Murre. In both cases (human and murre distribution), 

there is a strong population concentration from Monterey to Marin County. South of 

Monterey County, there are no murre colonies. North of Marin County, there are few 

murre colonies until Humboldt County. The duration of the project was scaled using 
 N-9 

a population model of the Central California murre population, comparing the 

benefits of increasing nest success to the loss of breeding birds associated with the oil 

spills. The model includes information regarding juvenile, sub-adult, and adult 

survival from the Farallon Islands, and thus allows for an examination of how each 

demographic parameter influences population growth. Specifically, the modeling 

shows that a project that lasts 20 years and increases fecundity by 5% would 

compensate for 38 percent of the injuries to this species from the spill. There are two 

other projects described in the plan that also address injuries to murres. We are 

satisfied with our scaling effort and the conclusion that this project is sufficient to 

compensate in part for injuries to Common Murres. 

The cost of the project is based upon pre-existing pilot project costs and similar work 

conducted on behalf of the Apex Houston and Command Trustee Councils, as well as 

on a similar project in Oregon. Considering the duration of the project (20 years), we 

consider the cost to be reasonable and proportionate to other restoration work. 

 

We expect this project will mirror the success of a program developed in Oregon to 

protect nesting seabirds at Three Arches National Wildlife Refuge. Monitoring 

during the breeding season following the implementation of that disturbance 

reduction program revealed a 39% reduction in disturbance events. 

This project will be an expansion of the pilot project that is currently being funded by 

the Command Oil Spill Trustee Council. The Command council is funding the 

project for four years with the first two years being mostly project development. This 

project will take the Command project and extend it for 20 additional years. 

Agencies such as the USFWS and BLM do not have funding available to address the 

disturbance problems at these colonies. 

The goal of the Apex Houston Common Murre Restoration Program (CMRP) has 

been to restore historic murre colonies at Devil’s Slide Rock, San Pedro Rock, and 

Castle and Hurricane Point Rocks. That project was not developed to address the 

issue of human disturbance at those colonies. The CMRP has, in the course of their 

restoration work, been instrumental in identifying the significant threat that human 

disturbance poses to Central California murre colonies. That project, however, does 

not have the funds or dedicated staff that the Luckenbach project will contain to 

adequately address this threat. We agree that this project requires a large investment 

in order to be successful; the long duration of this project will thus be an asset toward 

its success. 

Corvid Management to Protect Common Murres 

One commenter suggested that the corvid removal aspects of the Point Reyes Corvid 

Management Project should be extended to include work at other active and historic 

Common Murre colonies in Central California. 
 N-10 

Trustee Reply: 

We agree that it would be beneficial to consider targeted corvid removal at murre 

colonies and have included this as a deferred secondary component of the Seabird 

Colony Protection Project in Central California. This means that limited removal of 

problem corvids will be evaluated and considered as an adaptive management 

component of the project and may be implemented if needed in the future. 

Marbled Murrelet Restoration 

One commenter expressed concern that the proposed projects for Marbled Murrelets will 

not provide sufficient compensation for the injury to this species. Specifically, the 

amount of habitat protected is too small and the corvid management project may not yield 

increased breeding success. The commenter suggested that the Trustees host a workshop 

of agency personnel and outside experts to discuss specific murrelet restoration concepts. 

Another commenter noted that any habitat purchased for Marbled Murrelets should be 

conveyed to an organization that will manage it in a way that will guarantee preservation 

for murrelets and to avoid organizations whose primary focus is human recreation. 

Trustee Reply: 

We have scaled the murrelet nesting habitat protection project based upon a detailed 

murrelet population model (developed during the Kure and Stuyvesant oil spill 

NRDAs) and using demographic parameters derived from the Santa Cruz Mountain 

population. To buttress our assumption that nests protected will be productive nests 

(i.e., producing enough birds to offset mortality), we have also proposed continuing 

funding of the existing (ongoing) corvid management project in the Santa Cruz 

Mountains. While this corvid management project is still in its early stages 

(implemented by the California Department of Parks and Recreation (CDPR) and 

funded by the Command Trustee Council), early results suggest that the key project 

components can be implemented and that raven numbers and reproduction have 

declined in the targeted areas as a result of the project. We believe that our scaling 

exercise that resulted in the conclusion that 140 acres (benefiting 7 nests) are 

sufficient to compensate for injuries to the Marbled Murrelet is sound. Regarding the 

assumption about productive nests and the success of the on-going corvid 

management project, we are monitoring that project closely and will employ adaptive 

management strategies if the reductions in corvids around campgrounds are not met. 

We selected these two projects based upon a trustee/expert workshop like the one 

suggested, as well as on continuing discussions with murrelet experts in the course of 

this and other NRDA cases. The workshop was held in October 2002 at Henry 

Cowell Redwoods State Park and was convened by the Command Trustee Council. 

The focus of the workshop was the restoration needs of the Marbled Murrelet in the 

Santa Cruz Mountains. Participants included many of the prominent murrelet experts 

in Central California, including Steve Beissinger, Esther Burkett, Rick Golightly, 

Tom Hamer, Laird Henkel, Zach Peery, Steve Singer, Gary Strachan, and David 

Suddjian. Additional personnel from CDFG, CSLC, USFWS, CDPR, and USGS 

were also present. Various participants in the workshop identified corvid 
 N-11 

management and habitat protection as the two most feasible and important restoration 

options for murrelets in the Santa Cruz Mountains. 

With respect to habitat protection, no specific parcel has been identified for 

protection/acquisition and no decision has been made regarding which agency or 

organization should take over ownership and/or management. That said, CDPR is the 

dominant public landholder in the vicinity of murrelet nesting habitat in the Santa 

Cruz Mountains. Trustees in other oil spill cases have acquired land for murrelet 

nesting habitat protection in this area on two prior occasions: 1) The Apex Houston 

Trustee Council contributed to the acquisition of the Gazos Mountain Camp parcel 

(110 acres); and 2) the Command Trustee Council contributed to the acquisition of 

the Girl Scout Creek parcel (80 acres). In both instances, CDPR agreed to take 

ownership and management guidelines were created with the intent to enhance 

protection of the Marbled Murrelet. While there have been concerns expressed over 

the interpretation of guidelines in the former case (and involved agencies have 

revisited those guidelines to address the balance of habitat and recreational values), 

we believe that murrelet nesting will not be compromised with implementation of the 

appropriate management actions. In the latter case, the guidelines have been made 

more explicit and the legal tools strengthened in order to prevent confusion and 

ensure that management decisions potentially affecting the murrelet will be made 

jointly among CDPR and other trustee agencies. While CDPR does have a mission to 

promote public recreation as one of its goals, it also lists “helping to preserve the 

state’s extraordinary biological diversity” and “protecting its most valued natural 

resources” as goals in its mission statement. This is consistent with its statutory 

authority over, and management responsibilities concerning state “natural reserves” 

and “natural preserves” pursuant to Public Resources Code sections 5019.65(a) and 

5019.71, respectively. CDPR’s leadership in implementing the corvid management 

project at Big Basin, Butano, and Portola State Parks has been exemplary. 
Appendix O: Public Comments 

This appendix contains copies of the written public comments received, in the following 

order: 

1. Harry Carter, Mar 1 

2. Josh Adams, Apr 14 (and Semidi Island project description) 

3. Donald Croll, Apr 14 

4. Harry Carter et al, Apr 14 

5. R. William Henry, Apr 14 

6. Brad Keitt, Apr 14 

7. Hannah Nevins, Apr 12 

8. Nancy Lenz, Apr 7 

9. Al Smith, Apr 9 

10. Edwin Aiken, Apr 7 

11. Bill Hunt (Parks Canada), Apr 4 

12. Sarah Johnson, Apr 9 

13. Craig Harrison (Pacific Seabird Group), Apr 13 

14. Julie Heffington (Seymour Center, Long Marine Lab), Apr 6 

15. Jim Rourke, Apr 14 
1

To: Steve Hampton (CDFG-OSPR) 

From: Harry Carter (Carter Biological Consulting, 1015 Hampshire Road, Victoria, 

British Columbia V8S 4S8 Canada; 250-370-7031) 

Date: 1 March 2006 

Re: Public comments on Luckenbach Draft Restoration Plan 

In response for your request for public comments on this draft plan, I offer the following 

from a brief scan but please contact me to discuss further as needed: 

- Public Review Process: It is unreasonable to expect to get many detailed public 

comments from such a large document. To augment expected limited public 

comments, it would be appropriate to contract with selected experts to ensure 

reasonable and detailed review of proposed projects. Detailed review by 

experienced experts in the species and sites involved is critical to ensure adequate 

planning for many of these restoration projects presented in such a large single 

draft plan. While it is great to see such a major effort to restore seabirds and many 

good projects are identified, a few examples of major plan flaws in areas most 

familiar to me that rapidly came to mind are outlined below. 

- Mouse eradication at the South Farallon Islands: This project has not been well 

justified or planned. The degree of direct mouse predation on Ashy Storm-Petrel 

nests has not been properly described from available literature (Ainley and 

Boekelheide 1990) or unpublished data and is lower than implied. Disappearance 

of petrel eggs occurs at Santa Cruz Island when no mice are present and 

apparently results to a great extent from adults removing eggshells after breakage. 

Thus, egg disappearance cannot be assumed to result entirely from mouse 

predation. Removal of house mice likely will reduce predation by small numbers 

of owls but there is no mention of the fact that most petrel predation is from the 

tens of thousands of breeding Western Gulls. Successful restoration of Ashy 

Storm-Petrels will not occur from mouse eradication and reduced owl effects, 

unless the gull predation issue is also addressed to a significant degree. This point 

has been discussed many times by trustees and others so to omit this problem in 

this draft plan is improper. As a relatively low-cost solution and addition to the 

mouse eradication project, I suggest that both habitat restoration and removal of 

problem-individual gulls would help address gull predation. Much loss of nesting 

habitat occurred in the 1800s when rocks were collected to make walls and 

buildings on the island (Carter et al., in review. Ashy Storm-Petrel. In: California 

Bird Species of Special Concern). This habitat change forced petrels into nesting 

in concentrated areas where avian predators can focus their efforts. From working 

for several years on the South Farallon Islands in the 1980s, I saw many dead 

petrels at certain problem-individual gull nests: a) located near rock walls where 

petrels nest; b) around researcher quarters and the power house where gulls on 

nearby nests eat petrels in lighted areas; and c) located near human-impacted 

areas where gulls can dig out birds from shallow nest sites. By spreading out 

predator-proof petrel nesting habitat (especially in areas without gulls or with few 

gulls), removing small numbers of problem-individual gulls, eradicating mice, 
2

and reducing owl predation, future predation risk would be reduced to a great 

degree. To mimic natural conditions, small amounts of artificial nesting habitat 

for Ashy Storm-Petrels (e.g., low maintenance cement slabs with sufficient space 

to allow petrel use but not allow access by auklets or gulls, plus allow access for 

monitoring without dismantling the site) need to be placed all over the South 

Farallon Islands. At these sites, petrels would be better protected by reducing 

direct predation of adults entering and departing from sites, as well as preventing 

gulls from digging out nest sites and consuming adults, eggs, and chicks on the 

nest itself. However, no visual or sound social attractants should be used to bring 

petrels to new sites because this would attract gull predators. Perhaps limited 

petrel odor could be used to speed attraction of birds to new sites. Overall, it 

would be better to let these sites be colonized gradually by petrels over time 

which will lead to long-term predation reduction. However, in the short term, 

problem-individual gulls need to be removed to provide immediate relief, 

especially where they occur near rock walls and buildings. The gull population is 

very large and loss of a few birds will not affect overall colony size. I have been 

working on similar habitat concepts for potential Ashy-Storm-Petrel restoration at 

Santa Cruz Island (with potential funding through the Montrose Trustee Council) 

and would be interested in working with others to devise artificial habitat and 

implement habitat restoration at the South Farallon Islands and Santa Cruz Island. 

- Corvid management to restore Common Murres at Point Reyes National 

Seashore: Removal aspects of this project should be extended to include work at 

other active and historic murre colonies at San Pedro Rock, Castle Rocks & 

Mainland and Hurricane Point Rocks. The Common Murre Restoration Project 

(CMRP) has noted substantial raven predation problems at Point Reyes and these 

other locations and has made substantial efforts to remove problem birds and 

nests at San Pedro Rock. However, this project does not have sufficient time and 

resources to continue to address this problem. I’d suggest that the CMRP should 

lead or cooperate with any new removal efforts at Point Reyes (and hopefully 

other colonies) because new efforts can benefit from their past experiences and 

the CMRP is already conducting monitoring of murres at Point Reyes and other 

colonies related to work for the Apex Houston and Command Trustee Councils. 

- Acquisition of old-growth forest nesting habitat and corvid management to 

restore Marbled Murrelets: The proposed projects will preserve insufficient 

habitat and have insufficient benefits to breeding success to have any long-term 

benefit to Marbled Murrelets. This population is in serious peril and a much 

greater improvement in nesting conditions is needed to prevent its extirpation in 

the near future, as currently predicted (McShane et al. 2004). While some efforts 

are being made through various trustee councils, the combined restoration benefit 

to Marbled Murrelets of all currently proposed or implemented projects in central 

California is likely to be zero because the population is likely to disappear, unless 

much greater restoration efforts are made to prevent population loss. Various 

restoration concepts have been considered by trustee agencies over several years 

which are not outlined as alternatives. I’d suggest further examination of 
3

restoration for Marbled Murrelets in the Santa Cruz Mountains through 

Luckenbach trustees hosting a specific workshop to discuss specific concepts with 

various agency staff and experts. I’m sure that better restoration planning would 

result, although increased funds and effort are likely involved. Marbled Murrelet 

restoration should be the most important restoration goal tackled with Luckenbach

funds but it has been improperly reduced to a small component. 

- Cassin’s Auklet Restoration: Proposed work at Mexican islands probably will not 

restore Cassin’s Auklets because their numbers have declined drastically due 

mainly to climate, oceanographic, and prey changes. Impacts of such natural 

phenomena likely will be greatest at the southern end of their distribution in Baja 

California where colonies already are largely abandoned. Any restoration efforts 

at these small colonies will likely not benefit Cassin’s Auklets in the near future, 

although long-term benefits of protecting vacant nesting habitat from human 

destruction would be attained. Very long-term monitoring would be needed to 

determine any future benefits but such monitoring is not likely in remote areas of 

Baja California. As a low-cost alternative, I suggest that Cassin’s Auklets should 

be instead restored at the South Farallon Islands. This very large colony has a 

perfect nexus with the Luckenbach, has declined due to climate change as well as 

high gull predation, and is located in an accessible area with long-term protection 

and monitoring (Ainley and Boekelheide 1990; Carter et al. 1992). Predation 

reduction through habitat restoration (i.e., widely providing predator-proof 

artificial habitat) and removing problem-individual gulls and owls would have 

great benefits to this declining population and would only be a small extension of 

that proposed above under Ashy Storm-Petrel. I have been working on similar 

concepts for potential Cassin’s Auklet restoration at Santa Cruz Island (with 

potential funding through the Montrose Trustee Council) and would be interested 

in working with others to devise artificial habitat and implement habitat 

restoration at the South Farallon Islands and Santa Cruz Island. 

 

 

 
Josh Adams 

190 Benito Ave. 

Santa Cruz, CA 95039 

Steve Hampton 

California Department of Fish and Game 

Office of Spill Prevention and Response 

1700 K Street 

Sacramento, CA 95814 

14 April 2006 

Re: Draft Assessment and Restoration Plan / Environmental Assessment for the S.S. 

Jacob Luckenbach and Associated Mystery Oil Spills 

Dear Steve Hampton, 

I would like to thank the Trustee Council for the Assessment and Restoration Plan / 

Environmental Assessment for the S.S. Jacob Luckenbach and Associated Mystery Oil 

Spills (hereafter, The Trustees) for coordinating damage assessment and restoration 

planning to recover the damages primarily to seabirds caused by the sinking of the 

Luckenbach. Thank you also for making this a public process and for encouraging public 

review and comment—prior to designing a Final Restoration Plan. 

Overall, the Draft Plan is well constructed and presents a wide variety of projects that 

will aid in the recovery of damages for some of the affected seabird species. It is my 

opinion that true “restoration” should have significant benefits to populations affected or 

targeted, and that these benefits should always be measured and evaluated. I encourage 

The Trustees to preferentially select restoration projects that will have the greatest lasting 

benefits for affected populations, and if such restoration projects can achieve multiple 

species or ecosystem-level benefits—these should be encouraged and given first priority 

over plans that target single-species or less significant driving factors of species 

population change or ecosystem function. 

The birds affected during this event include many that visit the affected central coast 

offshore area during the winter—many of these birds breed far from California and 

restoration activities will be most effective at colonies or breeding locations. One of the 

most effective restoration actions for seabirds, seabird communities, and island 

ecosystems in general, is to remove non-native invasive species that significantly alter 

island ecosystem function by such means as removing seabird biomass through time and 

thereby initiating irreversible changes to entire floral and faunal communities. Such 

communities often support rare, endemic members that comprise biologically diverse 

assemblages. Provided with the opportunity to remove introduced species from island 

ecosystems, this action should always rank as a top priority for restoration. I support the 

Trustee’s plan to support the eradication of non-native predators from Southeast Farallon 

Island and the Queen Charlotte Islands. 
I do not think that the plan to evaluate and attempt to minimize disturbance to seabirds 

(primarily Common Murre and Brandt’s Cormorant) off central California achieves a 

high level of true restorative value. Of course I am entirely in favor of reducing 

disturbance to nesting seabirds, but evaluation of success and true measurable benefits to 

target populations are hindered by our lack of understanding regarding what factors truly 

regulate these populations (i.e., juvenile, sub-adult, and adult survival, etc.). 

Furthermore, evaluation and reduction of disturbance to nesting seabirds has been one of 

the main objectives for existing programs, agency tasks, and law enforcement. It is my 

view that the Draft plan for the central California portion to reduce disturbance to 

seabirds be re-evaluated with close attention to true restoration benefits that are scaled to 

the proposed funding amount in this category. 

Additional consideration for effective restoration actions that address species affected 

should be considered. Attached to this letter is one such suggestion that would benefit a 

suite of species affected by the sinking of the Luckenbach by restoring important island 

ecosystems in the Gulf of Alaska. The construction of this potential project was 

encouraged by the Trustee’s at the public meeting held in San Francisco on 14 March 

2006. The ideas and information therein have been discussed and evaluated by USFWS 

invasive species experts at the Alaska Maritime National Wildlife Refuge. Any 

comments or questions should be directed to me at 831-771-4138 (phone) or to Steve 

Ebbert, Wildlife Biologist, Alaska Maritime National Wildlife Refuge, 907-235-4610 

(phone). 

Thank you, 

Josh Adams 

 

cc: Steve Ebbert, USFWS, Alaska Maritime National Wildlife Refuge, Homer, Alaska 

attached: Draft Proposed Plan: The removal of introduced arctic ground squirrel 

(Spermophilus parryii) from the Semidi Islands, Alaska to recover multi-species damages 

resulting from oiling events attributed to the sunken freighter S.S. Jacob Luckenbach 
Draft Proposed Plan – Please do not cite material herein without permission 

1

Draft Proposed Plan: The removal of introduced arctic ground squirrel 

(Spermophilus parryii) from the Semidi Islands, Alaska to recover multi-species 

damages resulting from oiling events attributed to the sunken freighter S.S. Jacob 

Luckenbach 

Preliminary Draft prepared by Josh Adams with review and comment by Steve Ebbert 

14 April 2006 

 Background 

From August 1990 through December 2003 repeated oil spill events attributed to the 

sunken freighter S.S. Jacob Luckenbach killed an estimated 51,000 seabirds off central 

California. Of 50 species of birds impacted, Northern Fulmar dominated the impacted 

procelariiform seabirds (94% of recovered specimens among 8 procelariiform 

species/groupings). Other species impacted include a suite of aclids: Common Murre, 

Rhinoceros Auklet, Ancient Murrelet, Cassin’s Auklet, and lesser numbers of Pigeon 

Guillemot and Tufted Puffin. This assemblage represents a significant proportion of the 

marine avifaunal community of the Semidi Islands within the Alaska Maritime National 

Wildlife Refuge (AMNWR) ecosystem. We propose to directly recover damages caused 

by the wreck of the S.S. Jacob Luckenbach to multiple seabird species by removing 

introduced arctic ground squirrels from the Semidi Islands. 

 Conservation Issues 

Alaska Maritime National Wildlife Refuge arguably is the premier seabird refuge in the 

world. Approximately 80% of the estimated 50 million breeding seabirds in Alaska nest 

on Alaska Maritime Refuge’s more than 2,500 islands, islets, rocks, and headlands. 

Unfortunately, many islands have suffered extreme ecosystem altering effects from 

introduced mammalian predators including foxes, arctic ground squirrels, rats, deer mice, 

voles, and shrews. Although most rodent introductions were accidental, fox ranchers 

intentionally stocked other rodents such as ground squirrels either for fur harvest or as 

supplemental prey for foxes. 

The Semidi Islands, located 76 km southwest of Kodiak Island in the outer Shelikov 

Straight region of the Gulf of Alaska, consist of 9 islands that are among the Alaska 

Maritime National Wildlife Refuge’s premier seabird colonies. Five of the nine islands 

have ground squirrels: Aghiyuk, Anowik, Chowiet, Kateekuk, and Kiliktagik. 

Although exact wintering distributions are not known, many of the affected species that 

breed during the summer in Alaska migrate into the California Current System where 

they are vulnerable to winter oil pollution. For example, recent evaluation of beachcast 

Northern Fulmar carcasses deposited in central California indicate that based on color 

morph ratios (majority dark phased), the majority of birds described likely originated 

from Gulf of Alaska colonies, of which the Semidis host the vast majority of breeding 

pairs (H. Nevins pers. comm.). Furthermore, satellite telemetry applied to post-breeding 

adult fulmars marked on the Semidis showed dispersal to the California Current and areas 

affected during wintertime oiling events (S. Hatch unpublished data). Rhinoceros 
Draft Proposed Plan – Please do not cite material herein without permission 

2

Auklets, Ancient Murrelets, Cassin’s Auklets, Glaucus-winged Gulls are also suspected 

to be migrants from Gulf of Alaska colonies. 

 Injury Calculations 

Summarized here is the injury calculation for a partial species assemblage that was 

affected by the S.S. Jacob Luckenbach. This assemblage occurs at the Semidi Islands, 

Alaska, and we propose that the following seven target species are likely to benefit from 

the proposed restoration project that seeks to recover damages to this multi-species 

assemblage. A total of 375 procellariiform seabirds were collected during the spills that 

occurred between 1997 and 2003. Additional birds were collected between 1990 and 

1996, however information regarding species composition for this time period is limited. 

The total estimated dead procelariiform seabirds from all spills is 5,703 (assuming 94% 

were Northern Fulmar, this equates to 4,506 fulmars); at present, the draft plan does 

not address restorative compensation for this species. Glaucous-winged Gull was the 

second most affected species of the 11 Lariidae (assuming 16.5%, this equates to 393 

Glaucous-winged Gulls); at present, the draft plan does not address restorative 

compensation for this species. Cassin’s Auklet was the second most affected member of 

the Alcidae (1,509 estimated killed), followed by Rhinoceros Auklet (593 estimated 

killed), Ancient Murrelet (428 estimated killed), and other Alcidae (including Pigeon 

Guillemot and Tufted Puffin; 233 estimated killed). 

 Proposed Project 

Removal of arctic ground squirrels from the Semidi Islands NWR to benefit island 

ecosystems by protecting seabird nesting habitat 

This project targets existing USFWS Alaska Maritime NWR invasive species 

management goals and seeks to design and implement a focused program to eradicate 

introduced arctic ground squirrels from the Semidi Islands. 

Phase I – design and preparation for effective eradication 

• Determine distribution, abundance, foraging range, timing of emergence, food 

selection and key biological parameters for ground squirrels on Semidi Islands 

• Collect pre-eradication data on abundance, reproductive success, and ground 

squirrel-seabird interactions (includes integrating summary information collected 

since mid 1970s and partially supported by ongoing AMNWR monitoring) 

• Determine impacts of ground squirrels on seabird productivity and identify island 

priority for ground squirrel eradication. 

• Test potential toxicants, bait formulation, bait attractiveness and acceptance, and 

baiting strategies by arctic ground squirrels 

• Assist ongoing FWS efforts to design, test, and achieve regulatory compliance for 

effective, lethal ground squirrel baits 

Phase 2 – trial, evaluation, eradication, and risk assessment 
Draft Proposed Plan – Please do not cite material herein without permission 

3

• Conduct bait trial on smaller Semidi Island (i.e., one of the smaller islands such as 

Kateekuk or Kiliktagik) to verify bait strategy efficacy.1

 

• Evaluate non-target risk. 

• Eradicate ground squirrels from larger island(s) (i.e., Chowiet and Aghiyuk, on 

the order of $3.5M for both islands). 

Phase 3 – evaluating restoration success 

• Measure and report restoration success. 

• Recommend strategies for future eradications (i.e., Kavalga Island, Big Koniuji 

Island). 

The Alaska Maritime NWR has already initiated a program to address threats to island 

ecosystems by introduced invasive rodents, included within this program are necessary 

planning steps, surveys, studies, techniques, prevention measures, and outreach. Major 

elements of this program include: National Environmental Policy Act (NEPA) 

compliance, state and federal rodenticide registrations, rodent quarantine measures, nontarget hazard evaluation, ecosystem recovery documentation, and public outreach. All 

methods will be evaluated and subject to review and guidance by the National Invasive 

Species Council (NISC) and guided by established DOI and FWS policies to ensure that 

activities are coordinated, safe, and effective. Alaska Maritime NWR invasive species 

biologists have completed initial bait trials targeting ground squirrels (S. Ebbert pers. 

com.). Pesticide registration staff (National Wildlife Research Center) together with 

USFWS have worked to secure EPA registrations for two rodenticides (brodifacoum and 

diphacinone) for the expressed use of eradicating rodent populations from islands to 

protect native flora and fauna. 

Anticoagulant baits (brodifacoum and diphacinone) already are recommended for 

controlling ground squirrels in some states, and the AMNWR has made progress toward 

achieving permission and permitting to use these rodenticides for eradicating invasive 

rodents on refuge islands. Funds made available during past Oil Spill restoration Trustee 

councils have or are currently being used to apply similar methods toward restoring 

island impacted by introduced invasive species. For example, the American Trader 

Restoration Council supported the complete removal of introduced ship rat (Rattus 

rattus) from Anacapa Island in the Channel Islands National Park, and the Command 

Trustee Council is currently supporting the removal of ship rats from globally significant 

islands off southern New Zealand. Once completed, these programs are recognized 

world-wide as having extraordinarily beneficial ecological outcomes that can be rapidly 

documented with effective monitoring. 

 

1

 According to FWS invasive species biologists, eradication of squirrels from Kiliktagik could easily be 

done with hand broadcast and bait stations. The actual application on Kiliktagik could take as few as two 

days, spaced a week a part or so, with several weeks of subsequent monitoring. 
Draft Proposed Plan – Please do not cite material herein without permission 

4

This program is unique and by necessity will require adaptive management to 

successfully achieve its goal of eradicating ground squirrels from the Semidi Islands. The 

selection for eradication strategies depends on the unique life cycle and behavior of 

ground squirrels. For example, baiting with treated grain is expected to be most effective 

in summer and fall because squirrels primarily feed on seeds during this period. 

However, it may be desirable to remove squirrels during the early spring when animals 

increase activity after hibernation and increase food demands while natural food 

availability in still low prior to reproduction. 

 Budget 

The total budget for this project would be scaled according to desired restoration goal; a 

full range estimate is $700,000 to $3,500,000. It would be implemented by the USFWS, 

USGS, NGOs, and private contractors as needed. This budget range includes additional 

project planning and permitting, implementation, and post-eradication monitoring. The 

Alaska Maritime National Wildlife Refuge will contribute in-kind services to assist in 

logistics and monitoring. 

 Scaling for Primary and Compensatory Restoration 

The total injury (>89,204 lost bird-years) resulting from the S.S. Luckenbach events to 

seabird species that occur in the Semidis is as follows: Northern Fulmar (72,470), 

Ancient Murrelet (1,867 lost bird-years), Rhinoceros Auklet (4,094 lost bird-years), 

Cassin’s Auklet (10,773), and Glaucous-winged Gull (not calculated in Draft DARP EA) 

 

 Affected Environment 

This project would be located within the Semidi Islands within the Alaska Maritime 

National Wildlife Refuge. Alaska Maritime NWR maintains a seasonal research field 

station on Chowiet Island. This project would augment current long-term seabird 

monitoring efforts in the Semidis. The removal of arctic ground squirrels overseen by 

AMNWR would be conducted in full accordance federal, state, and tribal regulations and 

accords.2

 

 Environmental Consequences (Beneficial and Adverse) 

This project will benefit multiple species that were affected during the S.S. Jacob 

Luckenbach and will benefit the Semidi Island ecosystem by removing introduced arctic 

ground squirrel which negatively impact a unique and biologically diverse floral and 

faunal island community. 

This proposes action is not expected to result in any significant (i.e., population-level) 

adverse impacts. As in any program that seeks to eradicate an introduced invasive rodent 

with toxicants (anticoagulant baits), care must be taken to minimize the risk of secondary 

poisoning. There are no native terrestrial mammals inhabiting the Semidi Islands. This 

project will be designed to minimize risk to Bald Eagle, other predatory birds (raptors), 

waterfowl, raven, and additional passerines. 

 

2

 All the Semidi Islands are selected by the Koniag Corporation in accordance with ANSCA. The AMNWR 

is required to solicit Koniag Corporation for their views, but not necessarily consent, to a proposed 

management action such as the eradication of invasive species on their selected lands. 
Draft Proposed Plan – Please do not cite material herein without permission 

5

 

 Probability of Success 

The goal of the Refuge’s invasive species program is to protect and restore the natural 

diversity of refuge islands. This project is expected to have a high level of success and 

will help propel the Alaska Maritime NWR program toward it goal to remove introduced 

invasive rodents from additional Refuge islands. 

The Alaska Maritime NWR has a 50-year history of restoring island ecosystems by 

eradicating introduced mammals from Refuge lands. Preventing new introductions of 

exotics and removing existing infestations are the most effective management actions to 

protect the native wildlife given in trust to Refuge stewards. Foxes were the most 

widespread invasive mammal on the Alaska Maritime Refuge and they were the first 

non-native predator targeted for eradication. Since the mid-1970s, foxes have been 

removed from one or two islands annually. Aleutian Canada geese were reintroduced to 

fox-free, former nesting islands and the population of increased from 300 to 30,000 

allowing FWS to remove the species from the endangered species list in 2001. 

Evermann's rock ptarmigan, a rare subspecies that survived fox introduction on only one 

island, recently established a new population on Agattu Island, now fox-free, after the 

refuge transplanted them there in 2003 and 2004. Seabirds quickly re-colonized the 

larger islands after fox eradication. Additionally, waterfowl, shorebirds, ptarmigan, and 

possibly passerines increase following fox eradication. Judging from the responses in 

monitored areas, the project to remove alien foxes has likely increased populations of 15 

to 20 bird species by more than 200,000 individuals. 

 Performance Criteria and Monitoring 

We propose a phase-based approach to assess the success and ecological post-eradication 

responses based on long-term monitoring protocols already in place. 

 Invasive Species on the Alaska Maritime National Wildlife Refuge 

Seabirds often breed in colonies on islands that have evolved without mammalian 

predators, and therefore, seabirds are inherently vulnerable to introduced invasive 

mammals. Like most of the islands throughout the Pacific, many islands of Alaska 

Maritime NWR have not been spared the devastating effects of non-native predator and 

ungulate introductions. Alien or non-native wildlife introductions began more than 200 

years ago, soon after the Russians first visited Alaska and continued until just after World 

War II. As early as 1750, Russian merchants intentionally released arctic and red foxes 

onto many large Aleutian Islands that had seabird colonies. After the Aleutian Islands 

became a wildlife refuge in 1913, refuge management initially encouraged fox ranching. 

Between 1900 and 1929, lease-holders and trappers released foxes on islands. By the 

end of the fox-ranching era, nearly every island with beach access south of the Alaska 

Peninsula and in the Aleutian Islands was stocked, and ground nesting birds were 

extirpated or reduced to low population levels over broad ranges. Rats invaded several 

islands as recently as World War II. Foxes were stocked on islands with bird colonies as 

late as 1945 for fur ranching. Caribou were released on Adak Island in the late 1950s. 

Foxes and rats have caused significant impacts to Alaskan seabird populations. Entire 

colonies were wiped out by just a few hungry animals. For example, foxes that managed 
Draft Proposed Plan – Please do not cite material herein without permission 

6

to cross pack ice during the early 1970s, wiped out the large murre colony at Walrus 

Island in the Pribilof Islands. 

Arctic ground squirrels (Spermophilus parryii) were farmed on some islands for the same 

reasons foxes were raised—as a source of marketable furs. Kavalga Island in the 

Aleutians is a clear example of where ground squirrels were introduced; although 

Kavalga is the first island targeted for restoration by ground squirrel removal, the Semidi 

Islands currently are impacted and present a clear nexus to the seabird assemblage 

affected by oiling from the S.S. Jacob Luckenbach. Grounds squirrels are known to prey 

on eggs and chicks of waterfowl and seabirds. Whereas storm-petrels and other burrow 

nesters are absent or greatly reduced on Semidi Islands with ground squirrels (Chowiet, 

Kaliktagik), nearby islands without ground squirrels retain these species in extraordinary 

abundance (Suklik). Once ground squirrels are removed from the Semidis, slope and 

burrow nesting seabirds (e.g., Northern Fulmar, Rhinoceros Auklet, Ancient Murrelet, 

and Forked-tail and Leach’s Storm-Petrel) and waterfowl (e.g., Common Eider, and the 

Semidi form of the Aleutian Goose3

) likely will benefit and over time may reoccupy the 

coastal bluffs, vegetated foreshore areas, and island interiors. Additional species such as 

Glaucous-winged Gull, Black Oystercatcher, and several ground-nesting passerines also 

are expected to benefit. 

 

3

 Despite protection on both the breeding and wintering grounds, the small group of Aleutian Canada geese 

nesting in the Semidi Islands has been unable to increase its population above the high point of 120 birds 

achieved in 1993. Poor survival rates among young birds appear to be behind this lack of growth. 

http://alaska.fws.gov/media/finalqanda.html 
 UNIVERSITY OF CALIFORNIA, SANTA CRUZ 

 

BERKELEY • DAVIS • IRVINE • LOS ANGELES • RIVERSIDE • SAN DIEGO • SAN FRANCISCO 

 

 SANTA BARBARA • SANTA CRUZ

DEPARTMENT OF ECOLOGY & EVOLUTIONARY BIOLOGY

DIVISION OF NATURAL SCIENCES 

CENTER FOR OCEAN HEALTH, LONG MARINE LABORATORY 

100 SHAFFER RD. 

SANTA CRUZ, CALIFORNIA 95060 

April 14, 2006 

Dear Luckenbach Trustee Council: 

 I have studied marine birds and mammals in the waters impacted by the Luckenbach oil 

spill for more than 27 years. I am familiar with the ongoing oiling incidents which have now 

been attributed to the S.S. Jacob Luckenbach and applaud the agencies responsible for 

tracking down the source and assessing the damages to our natural resources. 

 The 13 proposed restoration projects are broad in scope and attempt to mitigate for the 

majority of the estimated damages to both birds and mammals. I am especially supportive of 

the Trustees’ proposals that attempt restoration at a species breeding location, even if it 

outside of the spill impact zone. Many of the seabirds that use the marine waters between San 

Francisco and Monterey are winter visitors from outside the area. By focusing restoration 

efforts at the breeding colonies, regardless of their location, the Trustees are able to suggest 

projects that will have the maximum benefit for the money spent. By protecting these species 

where they breed the Trustees are guaranteeing that future generations will continue to 

observe and enjoy them long into the future. In addition, by restoring the population numbers 

of impacted species the Trustees will maintain the important role these species play in the 

marine ecosystem off the coast of San Francisco. 

 The main recommendation that I would suggest that the Trustees consider is the 

importance of monitoring the changes attributed to their projects. It is important to demonstrate 

the effects of the projects they are proposing as well as providing baseline information for 

future assessments of the natural resources in the region. 

Thank you for this opportunity to comment on the Draft Restoration Plan for the S.S. Jacob 

Luckenbach. 

Sincerely, 

Donald A. Croll, Ph.D. 

Associate Professor
1

Steve Hampton 

California Department of Fish and Game 

Office of Spill Prevention and Response 

1700 K Street, Suite 250 

Sacramento, CA 95814 USA 

14 April 2006 

Re: Public comments on Draft Restoration Plan/Environmental Assessment for S.S. Jacob 

Luckenbach and Associated Mystery Oil Spills 

Dear Members of the Luckenbach Trustee Council: 

As seabird biologists concerned with research and conservation of the Xantus’s Murrelet, we 

have reviewed the proposed seabird restoration projects related to Luckenbach oiling events and 

here provide our public comments. We are very supportive of the project “Seabird Restoration 

and Protection on Baja California Islands, Mexico” for the benefits it will provide for the 

Xantus’s Murrelet. However, we recommend that additional focus be placed on restoring 

Xantus’s Murrelets and that this species should become a target species for restoration in the 

proposed activities for this project. Much of the world Xantus’s Murrelet population spends the 

non-breeding season in late summer and fall off central California where Luckenbach oilings 

occurred. No oiled Xantus’s Murrelet carcasses were recovered and thus this species has not 

been considered a main target species of the restoration plan. However, this species was almost 

certainly killed by Luckenbach oilings based on timing and location of oiling events in relation to 

murrelet at-sea distribution. During the non-breeding season, Xantus’s Murrelets tend to occur 

mainly on the middle and outer parts of continental shelf in central California where they would 

have a high probability of Luckenbach oiling but oiled carcasses have a low likelihood of 

beaching and any beached carcasses have a high scavenging rate and a low probability of 

detection. Especially given its Mexico endangered status, California state threatened status, and 

candidate U.S. status, we feel that the Xantus’s Murrelet also should be considered a focal 

species for restoration. 

The current project proposes restoration activities for pelicans, cormorants, and Cassin’s Auklets 

that also will benefit Xantus’s Murrelets. Specifically, beneficial restoration activities at three 

important Xantus’s Murrelet breeding colonies (i.e., San Martín, San Jeronimo, and San Benito 

Islands) should be very effective in reducing injury to murrelets and increasing their breeding 

success at these colonies. These include a) prevention of reintroduction of cats or rats which have 

likely caused great reduction in Xantus’s Murrelet population size, especially in Mexico; b) 

protection of Cassin’s Auklet nesting habitats because Xantus’s Murrelets likely breed in auklet 

burrows to a limited extent; c) shielding light sources on colonies will likely reduce collisions of 

adults or disorientation of chicks as they depart from the colony; d) education/outreach to reduce 

human disturbance; and e) protection and restoration of native vegetation may allow for 

continued or future use of shrub nesting habitat. We are very supportive of all these activities, 

particularly for their restoration benefits to murrelets. 
2

We also recommend additional restoration activities for Xantus’s Murrelets: f) reducing and 

shielding nocturnal light sources at sea near colonies, which would benefit the Cassin’s Auklet as 

well; and g) efforts to recolonize Xantus’s Murrelets at San Roque and Asunción Islands where 

most recent surveys in 1999 were not able to detect presence of Xantus’s Murrelets. We also 

recommend development of Xantus’s Murrelet monitoring programs at all islands to document 

long-term benefits from restoration activities. Since little or no baseline data exist and 

population changes may occur over a long time period, we suggest that 3 years of baseline data 

should be collected: a) population size should be measured at each colony using spotlight 

surveys; b) breeding success should be studied at San Benito Islands; and c) nest surveys should 

be conducted at other colonies as feasible. In addition, monitoring data would help identify other 

possible restoration actions that may be needed. Without adequate monitoring of Xantus’s 

Murrelets, benefits from restoration cannot be measured, assumed, or maximized. We feel that 

extensive benefits for Xantus’s Murrelets could be attained with greater funding and attention on 

this imperiled species. However, we also recognize that restoration actions should not be 

delayed until after baseline data is obtained and may need to be initiated before, during, or soon 

after restoration efforts. 

We again express our support for this project and ask the Luckenbach Trustee Council to 

consider even greater restoration actions and related monitoring to benefit Xantus’s Murrelets as 

feasible. Thank you for the opportunity to provide comments on this restoration plan. 

Sincerely, 

Harry R. Carter, 1015 Hampshire Road, Victoria, BC V8S 4S8 Canada 

Esther Burkett, 7119 Clearbrook Way, Sacramento, CA 95823 USA 

Lyann Comrack, 4646 Campus Avenue, San Diego, CA 92116 USA 

Frank Gress, 3408 Whaler Avenue, Davis, CA 95616 USA 

Tom Hamer, P.O. Box 2561, Mount Vernon, WA 98273 USA 

Christine Hamilton, 454 Deodar Avenue, Oxnard, CA 93030 USA 

Paige L. Martin, 14511 Knoll Ridge Drive, Tampa, FL 33625 USA 

Bill McIver, 454 Deodar Avenue, Oxnard, CA 93030 USA 

Elizabeth Mitchell, P.O. Box 933, Eugene, OR 97440 USA 

Darrell L. Whitworth, Via delle Vignacce 12, Staggiano 52030 Arezzo Italy 
 UNIVERSITY OF CALIFORNIA, SANTA CRUZ 

 

BERKELEY • DAVIS • IRVINE • LOS ANGELES • RIVERSIDE • SAN DIEGO • SAN FRANCISCO 

 

 SANTA BARBARA • SANTA CRUZ

DEPARTMENT OF ECOLOGY & EVOLUTIONARY BIOLOGY

DIVISION OF PHYSICAL AND BIOLOGICAL SCIENCES 

CENTER FOR OCEAN HEALTH, LONG MARINE LABORATORY 

100 SHAFFER RD. SANTA CRUZ, CALIFORNIA 95060 

Steve Hampton 

California Department of Fish and Game 

Office of Spill Prevention and Response 

PO Box 944209, Sacramento, CA 

Dear Mr. Hampton and Luckenbach Trustees, 

Figure 1. Interpolated geolocation track of adult incubating 

Guadalupe Laysan Albatross during oiling event (Jan 15-27, 

2006 RW Henry, Tagging of Pacific Pelagics). 

I am writing regarding wise investment of seabird 

conservation funds from the Luckenbach settlement. I am 

a native resident San Francisco Bay Area and currently in 

the Biology PhD program at UC Santa Cruz. My 

dissertation work focuses on tracking and contaminant 

loading of Laysan Albatrosses on Guadalupe Island, MX. 

As you know, seabirds sustained the most take during the 

Luckenbach legacy, these migrants are wide ranging and 

do not recognize international boundaries, frequently 

ranging multiple ocean basins. However, because they 

often spend little time at any given at sea location, it 

follows that wise conservation efforts should focus on 

areas that have high densities of seabirds and where increases population growth rates can be maximized. 

Specifically, effective conservation efforts should focus on breeding colonies. 

Seabirds breeding in Baja California Islands are known to disperse into central California. A case example 

involves the nascent population of Laysan Albatross breeding on Guadalupe Island, MX. In fact recent tracking 

studies show breeding albatrosses frequent the Luckenbach’s sphere of influence. In January 2006 a 

geolocation tracked albatross visited waters near the Luckenbach immediately following ocean conditions 

known to promote oil release. This tracked bird returned, freshly oiled, to resume its incubation shift on 

Guadalupe (Figure 1). Many other seabirds follow similar patterns on larger time scales: breeding on Pacific 

Islands off Mexico while spending nonbreeding periods in coastal of California. Many of these species, such as 

Brown Pelicans, are known victims of the Luckenbach. Other species, including this Laysan Albatross and 

others like the Xantus’ Murrelet are rare and likely went undetected during post spill monitoring events. It is 

these rarer species that are in most in need of conservation efforts. 

We also know that the benefits of restoration action at breeding colonies can far exceed at sea efforts. For 

example, modest investment in local feral cat control at the Guadalupe albatross colony halted cat predation of 

adult albatrosses. This mortality source alone was equivalent to ~10% of the annual North Pacific Longline 

Fishery Bycatch. 

In summary, if compensatory mitigation goals from the Luckenbach settlement aim to boost populations of taxa 

most injured from the spill, namely seabirds, protection and education at breeding colonies in the Mexican 

Islands of Baja California provides an unparalleled opportunity for effective and economical conservation of 

seabirds. Furthermore, funding conservation on Mexican islands warrants not only immediate action, but needs 

to support long-term monitoring to ensure lasting conservation benefits. 

Thank you, 

R. William Henry III 

henry@biology.ucsc.edu
Steve Hampton 

California Department of Fish and Game 

Office of Spill Prevention and Response 

1700 K Street, Suite 250 

Sacramento, CA 95814 USA 

14 April 2006 

Dear Members of the Luckenbach Trustee Council, 

 Thank you for the opportunity to comment on the draft restoration plan for the S.S. 

Jacob Luckenbach. I have reviewed the plan and wish to thank the council for developing 

such a thorough and comprehensive plan to mitigate for damages caused by the Luckenbach 

oil spill. I think it is important the council has made it a priority to maximize the benefits of 

the restoration actions by proposing to carry them out at the breeding sites of the species that 

were injured, even if these locations are not adjacent to the actual spill site. We know for a 

fact that the same birds that were damaged by the Luckenbach oil spill come from distant 

breeding locations such as Mexico and Canada. By targeting breeding sites the council will 

be able to achieve their restoration targets more quickly, with less money, and with greater 

guarantee of success in the short and long term. For these reasons I want to express my 

support for the “Seabird Restoration and Protection on Baja California Islands, Mexico” and 

for the Ancient Murrelet restoration projects. 

 Despite my support of the restoration plan as written there remain several issues I 

would like the council to consider. First, I think the council should prioritize restoration to 

species with limited ranges and smaller population sizes than more widely distributed and 

numerous species. Both Black-vented Shearwaters and Xantus’s Murrelets occur in the 

region where oil was spilled. While one Black-vented Shearwater was found, no Xantus’s 

Murrelets were recovered in the spill. However, because Xantus’s are small and are found 

near the shelf break they are less likely to wash ashore and be collected. Given the at sea 

distribution of Xantus’s Murrelets and Black-vented Shearwaters it is likely both these 

species were impacted by the spill. Fortunately, several of the proposed activities in the 

“Seabird Restoration and Protection on Baja California Islands, Mexico” will benefit both 

Xantus’s Murrelets and Black-vented Shearwaters. However, neither of these species are 

listed as targets for restoration. I request the council add these species as priorities for the 

restoration plan. Some additional activities beyond those already proposed could include 

efforts to re-colonize Xantus’s Murrelets at the islands of Asuncion and San Roque where the 

formerly bred, and trying to stop the development of new roads on the shearwater colony at 

Natividad. 

 In addition to adding direct actions to protect the murrelet and shearwater I also 

recommend the council include monitoring schemes to measure the benefits of the restoration 

activities they propose. 

Sincerely, 

Brad Keitt 

326 John Street 

Santa Cruz, CA USA 95060 
190 Benito Ave 

Santa Cruz, CA 95062 

April 12, 2006 

Steve Hampton 

California Department of Fish and Game 

Office of Oil Spill Prevention and Response 

1700 K Street, Suite 250 

Sacramento, CA 95814 

shampton@ospr.dfg.ca.gov

RE: S.S. Jacob Luckenbach DARP and Restoration Project 

Dear Steve & Luckenbach trustees; 

I attended the public meeting in the Presidio on March 14, 2006 where the trustees 

presented the draft S.S. Jacob Luckenbach DARP and proposed restoration projects and 

solicited requests for public comment. In this letter, I reiterated some of the same 

comments I made at the meeting because I think there are some important considerations 

regarding migratory seabirds. In general, I thought the case for the DARP was wellfounded and addresses damages to a diverse group of species. As a member of the 

research community in central California, I have personally recovered, documented and 

witnessed wildlife damages from the chronic winter oiling from the vessel Luckenbach 

and other mystery spills since 1997. I am very supportive of the trustees’ efforts to 

quantify and mitigate this chronic source of mortality and agree that is a good use of 

these funds to mitigate these damages with proposed restoration. I applaud your efforts. 

It is my intension to provide constructive criticism and offer some suggestions to aid the 

council in finalizing the damage claim for this serious impact to the California marine 

bird community. I have tried to be brief, so please contact me if you need further details. 

• Restoration of migratory seabirds was not addressed for species which nest 

outside of North America, most notably the shearwaters. Damages to pink-footed 

and sooty shearwaters, which nest in the southern hemisphere, have a number of 

well-defined conservation issues at colonies (e.g. habitat destruction, depredation 

by invasive species) and these restoration actions could be feasible, cost-effective 

and provide multi-species benefits. 

• Of the restoration categories [p.48], “Procellarids” is a varied taxomic group and 

should not have been lumped into one category for restoration purposes. The 

species affected within this group (i.e. fulmars, shearwaters, storm-petrels) have 

diverse life-history traits, habitat requirements, and will not all be addressed by 

the Farallon Islands Project. I am supportive of the Ashy Storm-petrel project, 

but this project will in no way benefit the other species within this restoration 
category. Restoration for the procellarids would most effectively be 

accomplished by addressing conservation issues in other regions (e.g. New 

Zealand, Chile) in addition to the Farallones. 

• I disagree with the statement that Ashy Storm-petrels are “more threatened” than 

Pink-footed Shearwaters and therefore merit the only restoration for procellarids 

[p. 50]. Because the ASSP is ranked based on a North American breeding status 

and by virtue of other species nesting in the southern hemisphere, they will never 

be ranked the same in this management construct. The PFSH is categorized as 

“Vulnerable” under ICUN listing and considerable effort has gone into 

determining conservation status by a tri-national committee, the council should 

re-consider a project to address damages to this species. There are many feasible 

alternative projects available for PFSH given funding. For example, see 

COSEWIC,1

 breeding habitat {attached document, p. 7}. 

• The restoration effort would benefit from inviting the participation of 

international stakeholders including Chile’s Corporación National Forestal 

(CONAF) for Pink-footed shearwaters, and Rakiura Maori (Indigenous New 

Zealanders) and Department of Conservation NZ for Sooty Shearwaters. 

• The council recognizes “shearwaters face various threats at colonies”, but notes 

that “...some of these issues are being addressed“ [p. 65]. I have been directly 

involved in the Command-funded shearwater restoration project mentioned in 

NZ, and while this project will greatly benefit the seabirds and ecosystems they 

inhabit, I would like to point out that there is much restoration work to be done to 

benefit this species. Specifically, I suggest funding for three small-scale projects 

to benefit this trans-Pacific migratory species which should be considered by the 

Luckenbach trustees: 

o Mainland Sooty Shearwater colony protection from invasive species. One 

of the few mainland colonies in NZ at Taiaroa Head, Dunedin, is in 

private ownership by Perry Reid and family. The colony holds less than 

200 nest sites, and is affected by grazers (sheep), disturbance from 

humans, non-native brush-tailed possums, hedge-hogs, rats, rabbits and 

other mammals. The colony is small enough to be surrounded by a 

predator-proof fence. Mr. Reid has agreed to have a fence built on his 

property and would maintain the fence and give access to researchers 

(through the University of Otago, NZ) provided that the council fund the 

material costs for the fence (expected cost: $20 to 50,000 USD). 

o Offshore North-Eastern Tïtï Islands – predator eradication. Bunker and 

Tia Islands are two of the few small (< 14 ha, 28 acres) islands with 

nesting Sooty Shearwaters where rats are present, and far enough away 

from the mainland to avoid re-invasion. Many shearwaters were killed 

chronic spillage by Luckenbach and other mystery sources, and genetic, 

 

1

 COSEWIC Status Report on the Pink-footed Shearwater Puffinus creatopus in Canada 2004. 
banding, and tracking studies link the at-sea population in central CA 

with nesting colonies in NZ (J. Adams & J. Harvey, unpublished data, C. 

Baduini, unpublished data). The ongoing Command-funded rat 

eradication will have made a substantial reduction in rat-infested island, 

but there are still some on the NE Tïtï Islands where rats are affecting the 

seabird and island ecosystems. These projects are of great conservation 

benefit and are often technically feasible, cost-effective, and have a high 

probability of success given the expertise of Pete McClelland and the 

Department of Conservation. (expected cost: < $200,000 USD) 

o Sooty Shearwater burrow- camera live linked for education in CA and 

NZ. The mainland colony at Acher’s Point, Stewart Island, has less than 

100 breeding pairs, but is accessible by trail to the public and an extensive 

on-going community-lead restoration project. This would be an ideal 

project to conduct outreach via remote camera at the colony showing 

birds on nest-sites in the study area. Such technology is relatively 

straightforward and in-expensive. I suggest a “sister-city” approach to 

connect NZ and CA visitor centers via web-based video feed. The 

Department of Conservation visitor center in Half Moon Bay, Stewart 

Island could serve as a public display area in NZ and a number of visitor 

centers in California including Half Moon Bay could be connected. Kari 

Beaven, Rakiura Community Trust would collaborate (estimated cost: 

<10k USD). 

• Staff and volunteer docents at the CA state parks in Monterey and Santa Cruz 

Counties have been directly responsible for recovering and transporting 

numerous oiled birds during the many years of chronic oiling. It would certainly 

benefit these staff and serve as an educational tool for the public to have simple 

displays about the number of past oiled wildlife and damages at visitor centers on 

themes such as “History of oil spills in CA”, “Clean beaches = healthy oceans”, 

“oiled wildlife, what you can do to help”. I recommend that some restoration 

funds go toward supporting educational facilities and outreach at state parks 

listed in the DARP in addition to educational materials listed under the 13 

proposed projects. 

• The Seabird Colony Protection Project seems entirely overly excessive in the 

budget, presents little demonstrable population-level effects, is too restricted in 

location (for the amount of funds requested) and may also be seen as duplicating 

ongoing efforts by the Command and other restoration councils. The technical 

feasible seems low given past success, and seems like it might be better suited to 

an ongoing base funding by an agency rather than a one-time restoration fund. 

Funding activities which should already be under the mandate of existing 

agencies (FCC, NOAA, BLM, USFWS) and will take a substantial amount of 

money away from efforts which would otherwise not be supported on a regular 

basis (e.g. predator eradication, conservation). The time to provide benefits also 

seems low, the Apex Houston funded murre colony project has been documenting 
disturbance since 1995 and yet problems continue. This suggests that there is a 

much longer-term investment needed. There is no mechanism by which the 

project with little criteria for evaluation and consideration of re-funding (i.e. reevaluation every 5-years). In general, I would suggest the council consider redirecting a great deal of the funds towards projects which have greater 

conservation value than the proposed outreach. 

• Finally, I would like to comment on the process - The process by which preplanning funding was allocated does not seem entirely transparent. For example, 

it is not readily apparent why some contracts, such as funding the scoping of 

certain projects was not made available to a wider public, such as in a request for 

proposals format. Simply put, it seems as though those projects developed with 

funds from the council prior to public review will be “favored” over other 

comments that brought in after the draft document has been put out for public 

review. 

• On a positive note, the council is forward-thinking in its approach to developing 

restoration projects in Mexico, Canada, and inland regions where much 

conservation value can be gained for the diverse migratory species affected by 

the chronic oiling off the California coast. In addition, mitigating habitat factors 

for snowy plovers and murrelets is valuable for the species, as is the mitigation of

un-naturally high levels of corvids near nesting areas. I commend the council for 

the diversity and complexity of issues addressed in this document. 

Thank you for allowing me to provide feedback to the trustees and be involved in the 

public process. I commend your efforts to promote seabird conservation for migratory 

species including waterfowl and Ancient Murrelets and look forward to hearing about 

your positive results in years to come. Should you require further information regarding 

my recommendations and comments, please contact me via email or phone. 

Sincerely, 

Hannah Nevins 

Seabird biologist 

hannah@oikonos.org

h 831.427.2540 

w 831.771.4422 
From: Nancy Lenz <nanlenz@cruzio.com> 

To: <shampton@ospr.dfg.ca.gov> 

Date: 4/7/2006 4:04:07 PM 

Subject: Lukenbach restoration project 

Dear Mr. Hampton: 

I would like to comment on the aspect of the Lukenbach restoration 

project that would provide an informational exhibit on sea otter health 

at the Seymour Visitors' Center at UCSC Long Marine Lab. 

I have been a volunteer at the visitors center for over 10 years 

guiding tours and interpreting exhibits. 

Our visitors are a curious lot and the more they learn about the 

oceans, the more they are looking for ways to help preserve and enhance 

our environment. Children and adults both are fascinated with the 

story of California sea otters -- how they almost faced extinction, how 

their fur must keep them warm while they are in the water, how their 

high metabolism requires them to search for food day and night. 

An exhibit that would help us explain to visitors the need to protect 

sea otters by preventing cat litter etc. from entering the ocean would 

be a positive step in informing the public about research that they 

could use to make changes in their waste disposal habits. 

Thanks for considering my opinion, 

Nancy Lenz 

230-B Pilkington Ave. 

Santa Cruz, CA 95062 

<nanlenz@cruzio.com> 
From: Al Smith <goneboating@webtv.net> 

To: <shampton@ospr.dfg.ca.gov> 

Date: 4/9/2006 9:29:35 AM 

Subject: S.S. Jacob Luckenbach Disaster 

Please add my name in Support of the subject Restoration Plan. 

I was an adult living in San Francisco in 1953: And now I'm a docent 

with Seymore Center, UCSC. I am also a Lifetime member of Friends of the 

Sea Otters. 

At the Seymore Center there is great public interest in Sea Otters and 

many questions about their status. On our outside tours at Seymour 

Center we often see Otters and that generates many comments and 

questions. Our visitors seem to want protection for all of their marine 

wildlife. 

 

Thank You for accepting public comments. 

Regards, Alfred Smith 
From: Ed and Jean Aiken <eandjaiken@sbcglobal.net> 

To: <shampton@ospr.dfg.ca.gov> 

Date: 4/7/2006 5:30:48 PM 

Subject: Support for Luckenbach DARP Sea Otter Project 

Dear Mr. Hampton, 

 

The purpose of this e-mail is to express my strong 

support for the "Sea Otter Pathogens Education and 

Outreach" project contained in the draft version of 

the Luckenbach Damage Assessment and Restoration Plan. 

The Seymour Marine Discovery Center in Santa Cruz is a 

particularly appropriate venue for locating the 

proposed kiosk to educate the public about the 

importance and vulnerability of the sea otter. I look 

forward to seeing this kiosk included among the many 

fine exhibits at the Seymour Center. 

Very truly yours, 

Edwin W. Aiken 

663 Torrington Drive 

Sunnyvale, CA 94087 

PROJECT: Sea Otter Pathogens Education and Outreach 

BENEFITS: Sea Otters 

This project would fund an education and outreach 

project in the Monterey Bay region to 

communicate to the public the threats posed to Sea 

Otters by various human activities. 

Recent scientific research has found that the current 

decline in California=s Sea Otters is a 

result of pathogens that enter the water through human 

and domestic animal feces. The 

project will suggest changes in how people manage pets 

and livestock, as well as boat 

and home septic tank systems. Cost: $120,000. 











P-1 

Appendix P: NEPA Compliance Documents 

Two documents are enclosed here: 

• Finding of No Significant Impact (FONSI) from NOAA 

• NEPA Decision Document/FONSI from USFWS for the Department of the 

Interior