2015 MSGP Biological Opinion F-1

Appendix F: Conservation Recommendations for Pacific 

Island Species
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Additional Avoidance and Minimization Measures for use in the Pacific Islands and Territories

.

I. All Pacific Islands:

Invasive species minimization measures (applies to Hawaii, American Samoa, Guam, and 

CNMI):

U.S. Executive Order 13112 (February 3, 1999) defines an “invasive species” as an alien species 

whose introduction does or is likely to cause economic or environmental harm or harm to human 

health. It further states the following: “Each federal agency whose actions may affect the status 

of invasive species shall, to the extent practicable and permitted by law”....”not authorize, fund, 

or carry out actions that it believes are likely to cause or promote the introduction or spread of 

invasive species in the United States or elsewhere unless, pursuant to guidelines that it has 

prescribed, the agency has determined and made public its determination that the benefits of such 

actions clearly outweigh the potential harm caused by the invasive species; and that all feasible 

and prudent measures to minimize the risk of harm will be taken in conjunction with the 

actions.”

The proposed actions, if not properly mitigated, may pose an increased risk for the introduction 

and establishment of invasive species into geographical areas that could negatively impact 

federally listed species and other trust resources. This broad directive has implications for nonFederal agencies as well, in particular to those working in partnership with Federal 

agencies. Therefore, the Service suggests that the project assess biosecurity risks associated with 

the movement of equipment and construction materials originating from outside a particular 

geographical area that would be used throughout the project. Any materials moving from Guam 

to any other island should be thoroughly assessed to ensure the brown treesnake is not 

transported in the material. As a means to implement feasible and prudent measures to minimize 

risk of harm, the application of Hazard Analysis and Critical Control planning is recommended 

to manage the risk of moving non-targets including invasive species.

Non-native mammals have the potential to adversely affect listed plants and animals. To avoid 

attracting non-native mammals to work sites, all workers should ensure their food scraps, paper 

wrappers, food containers, cans, bottles, and other trash from the project area are deposited in 

covered or closed trash containers. The trash containers shall be removed from the project 

area and disposed of off-site at an approved landsite at the end of each working day to prevent 

the attraction of non-native pests (i.e., rats). All tools, gear, and construction scrap will be 

removed upon completion of work in order to prevent the attraction of non-native pests (i.e., 

rats). No contamination (trash or debris disposal, non-native species introductions, attraction of 

non-native pests, etc.) of adjacent habitats will result from project-related activities. 

Sea Turtles

The proposed project is within the vicinity of nesting habitat for the endangered hawksbill turtle 

and threatened green turtle, collectively referred to as sea turtles. Sea turtles come ashore to nest 

on beaches from May through September, peaking in June and July. Optimal nesting habitat is a 

dark beach free of barriers that restrict movement. Nesting turtles may be deterred from 

approaching or laying successful nests on lighted or disturbed beaches. If they do come ashore, 

they may become disoriented by artificial lighting, leading to exhaustion and placement of a nest 
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in an inappropriate location (such as at or below the high tide line where nests are unlikely to be

successful). Hatchlings that emerge from unprotected nests may be disoriented by artificial 

lighting, move inland instead of toward the ocean, and not make it successfully to the ocean.

To minimize potential impacts to sea turtles that may utilize beaches in the project vicinity, no 

light from the proposed project should be visible from the beach. We recommend installation of 

shielded lighting at construction sites near beaches and around shoreline developments. Shielded 

lights reduce the direct and ambient lighting of beach habitats within and adjacent to the project 

site. Effective light shields should be completely opaque, sufficiently large, and positioned so 

that light from the shielded source does not reach the beach.

Habitat Occupied by Listed Plants

A qualified botanist should conduct botanical surveys prior to project implementation to 

document any listed plant species in the proposed disturbance area. Botanical surveys should be 

conducted during the wettest part of the year when target species may be more 

prevalent. Projects should be situated to minimize disturbance to listed plants and habitat 

suitable for listed plants. Unavoidable permanent impacts to plant habitat should be offset 

by restoring and conserving, in perpetuity, habitat to improve the recovery potential for the 

species impacted by the proposed project. Unavoidable impacts to listed plants can be offset by 

propagating the listed plants and common native plants and outplanting them to areas that are 

protected from ungulate browsing, wildfire, competition from invasive species, and other 

disturbances.

Critical Habitat The Service recommends adverse permanent impacts to critical habitat be 

avoided. Where critical habitat is temporarily impacted, measures to restore and conserve 

temporarily disturbed areas should be incorporated into project plans.

II. Guam and CNMI:

Mariana Crow (Rota only): Any clearing of vegetation should occur outside of the Mariana 

crow peak breeding and nesting season (August through February). No limestone forest should 

be removed to implement any of the proposed actions. Staff from the Service 

and Commonwealth of the Northern Mariana Islands Department of Fish and Wildlife (CNMI 

DFW) should be invited to inspect the property during vegetation removal to ensure no 

unanticipated habitat is removed.

Mariana Fruit Bat (Guam and CNMI): Because fruit bats are shot and killed by poachers, 

limit exposing bat locations to the public and to contractors. If a Mariana fruit bat is present 

within 492 ft (150 m) of the project site, the work must be postponed until the bat has left the 

area. Trees, which may serve as roost sites, should not be removed unless Guam or CNMI 

Department of Fish and Wildlife or Service biologists confirm the tree is not used as a bat roost.

Micronesian Megapode (CNMI), and Bridled White-eye (Guam): If a Micronesian 

megapode or bridled white-eye is present within 492 ft (150 m) of the project site, the work must 

be postponed until the megapode has left the area. If a megapode or bridled white-eye is nesting 

within 984 ft (300 m) of the project site, the work must be postponed and the Service contacted 

immediately as no nesting is known to occur there.
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Guam Rail (Rota and Guam) and Guam Micronesian kingfisher (Guam): To avoid adverse 

impacts to these species due to habitat loss to this species, do not clear vegetation on Guam 

beyond a 33-foot (ten-meter) wide swath. Clear no more than five acres of vegetation on each 

island.

Mariana common moorhen (Guam, Saipan, Tinian, Rota): Where work will occur near fresh 

water bodies, implement the following measures to avoid potential adverse impacts to the 

Mariana common moorhen: Pre-construction surveys should be completed one week prior to the 

onset of work by a biologist experienced in the identification of the waterbirds by sight and 

vocalizations and experienced with implementation of the Service protocol survey methodology 

to ensure no nesting moorhens are present. If nesting moorhens are present within 300 meters 

(m) (984 feet [ft]), clearing and construction should be postponed until chicks have fledged and 

the moorhen has left voluntarily. If work stops for more than one week, pre-construction surveys 

will be repeated to ensure that no moorhens have initiated nesting. On Guam, the Guam 

Division of Aquatic and Wildlife Resources (DAWR) personnel should be contacted at (671) 

735-3955 if a listed waterbird is detected at any time prior to or during the proposed action.

Nightingale reed-warbler (Saipan): Where noise greater than 60 dB or vegetation clearing is 

proposed, survey the project area for nightingale reed-warbler territories. If a territory is within 

328 feet (100 meters) of the project site, implement the following avoidance measures: Limit 

noise and vegetation clearing to months when breeding is less likely to occur (April through June 

and October through December) to avoid potential adverse impacts to breeding birds. To avoid 

impacts due to habitat loss to this species, do not clear vegetation beyond a 33-foot (ten-meter) 

wide area.

III. Hawaii:

Hawaiian hoary bat (Lasiurus cinereus semotus),Endangered

The endangered Hawaiian hoary bat may be present within the proposed project area. The 

Hawaiian hoary bat roosts in both exotic and native woody vegetation and will leave young 

unattended in "nursery" trees and shrubs when they forage. If trees or shrubs suitable for bat 

roosting are cleared during the breeding season, there is a risk that young bats could 

inadvertently be harmed or killed. To minimize impacts to the endangered Hawaiian hoary bat, 

woody plants greater than 15 feet (4.6 meters) tall should not be disturbed, removed, or trimmed 

during the bat birthing and pup rearing season (June 1 through September 15). Additionally, 

Hawaiian hoary bats forage for insects from as low as three feet to higher than 500 feet above the 

ground. When barbed wire is used in fencing, Hawaiian hoary bats can become entangled. The 

Service, therefore, recommends that barbed wire not be used for fencing or only within 2 inches 

of the ground surface as part of this propose action.

Hawaiian Waterbirds. Endangered Hawaiian stilt (Himantopus mexicanus knudseni), 

Hawaiian gallinule (Gallinula chloropus sandvicensis), Hawaiian coot (Fulica alai), Hawaiian 

duck (Anas wyvilliana) (collectively referred to as Hawaiian waterbirds). May occur in fresh and 

brackish water including streams, rivers, marshes, ponds, reservoirs, fish ponds, taro loi, 

impoundments, or other water sources. We recommend you incorporate the following measures 

into your project description to avoid and minimize impacts to listed Hawaiian waterbirds:
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A biological monitor should conduct Hawaiian waterbird and nest surveys at the proposed 

project site prior to project initiation (please see the Service’s recommended Hawaiian Waterbird 

Survey Protocols, attached).

A 100-foot buffer should be established and maintained around all active nests and broods until 

the chicks/ducklings have fledged. No potentially disruptive activities or habitat alteration 

should occur within this buffer. A biological monitor should be present on the project site during 

all construction or earth moving activities to ensure that Hawaiian waterbirds and nests are not 

adversely impacted.

If a listed Hawaiian waterbird is observed within the project site, or flies into the site while 

activities are occurring (within 100 feet), all potentially disruptive activities (including human 

activity, mechanical or construction disturbance) will be stopped until the animal(s) voluntarily 

leave the area.

Because the proposed activities may impact water resources that provide habitat for listed 

Hawaiian waterbirds, we are attaching the Service’s recommended Best Management Practices 

regarding sedimentation and erosion in aquatic environments. We encourage you to incorporate 

the relevant practices into your project design.

Hawaiian seabirds (Pterodroma sandwichensis), Endangered and Newell's 

shearwater (Puffinus newelli), Threatened

Hawaiian petrels and Newell’s shearwaters (collectively known as seabirds) may traverse the 

project area at night during the breeding season. Outdoor lighting at this project site could result 

in seabird disorientation, fallout, and injury or mortality. Seabirds are attracted to lights and after 

circling the lights they may collide with nearby wires, buildings, or other structures or they may 

land on the ground due to exhaustion. Downed seabirds are subject to increased mortality due to 

collision with automobiles, starvation, and predation by dogs, cats, and other predators. Young 

birds (fledglings) traversing the project area between September 15 and December 15, in their 

first flights from their mountain nests to the sea, are particularly vulnerable.

To minimize potential project impacts to seabirds during their breeding season, all outdoor lights 

should be fully shielded so the bulb can only be seen from below bulb height and only used when 

necessary. Automatic motion sensor switches and controls should be installed on all outdoor 

lights or lights should be turned off when human activity is not occurring in the lighted 

area. Any increase in night-time lighting, particularly during each year’s peak fallout period 

(September 15 through December 15), could result in seabird injury or mortality. Nighttime 

construction should be avoided during the seabird fledging period, September 15 through 

December 15. If nighttime construction occurs during other times of year, all lighting should be 

shielded and directed toward the ground to avoid attracting adult seabirds as they travel from the 

ocean to their breeding areas.

 

Blackburn’s sphinx moth (Manduca blackburni), Endangered

The adult moth feeds on nectar from native plants including beach morning glory (Ipomoea 

pescaprae), iliee (Plumbago zeylanica), maiapilo (Capparis sandwichiana). Blackburn’s sphinx 

moth larvae feed upon non-native tree tobacco (Nicotiana glauca), which occupies disturbed 
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areas such as open fields and roadway margins, and the native aiea (Nothocestrum sp.). We 

recommend that a qualified biologist survey the project area for the presence of larval host 

plants. To pupate, Blackburn's sphinx moth larvae burrow into the soil near host plants and can 

remain in a state of torpor for up to a year (or more) before emerging from the soil. In order to 

assess a project’s level of impact to this listed species, we recommend the area be surveyed for 

the presence of adult and larval host plants by a qualified biologist. To minimize the potential 

for the project to adversely impact the Blackburn’s sphinx moth, we recommend the host plants 

not be cut or removed and the soil within 10 meters (33 feet) of the host plants not be disturbed.