ENVIRONMENTAL ASSESSMENT

Bird Damage Management in Washington

Prepared by:

UNITED STATES DEPARTMENT OF AGRICULTURE

Animal and Plant Health Inspection Service

Wildlife Services

September 2011
TABLE OF CONTENTS

Chapter 1 PURPOSE AND NEED FOR ACTION....................................................................8

1.1 Introduction....................................................................................................................................8

1.1.1 Wildlife Acceptance Capacity ..................................................................................................8

1.1.2 Integrated Wildlife Damage Management (IWDM)..........................................................9

1.1.3 The WS Decision Model ............................................................................................................9

1.1.4 Cooperators ................................................................................................................................. 10

1.2 Bird Damage Management in Washington........................................................................ 10

1.2.1 Permits.......................................................................................................................................... 11

1.3 Purpose of the Environmental Assessment........................................................................ 11

1.4 Proposed Action......................................................................................................................... 12

1.5 Need for Action ......................................................................................................................... 13

1.5.1 Agriculture................................................................................................................................... 13

1.5.2 Human Health and Safety Concerns.................................................................................... 14

1.5.2.1 Human Health Concerns................................................................................................. 14

1.5.2.2 Human Safety Concerns ................................................................................................. 14

1.5.2.3 Property Damage............................................................................................................... 14

1.5.2.4 Protection of Natural Resources................................................................................... 14

1.6 Decisions to be Made............................................................................................................... 15

1.7 Scope of the EA......................................................................................................................... 15

1.7.1 Actions Analyzed....................................................................................................................... 15

1.7.2 Period for which this EA is Valid......................................................................................... 15

1.7.3 Site Specificity............................................................................................................................ 16

1.7.4 Resources Not Currently Protected by WS BDM............................................................ 16

1.7.5 WA Native American Tribes.................................................................................................. 16

1.7.6 Public Lands................................................................................................................................ 16

1.8 Laws and Regulations.............................................................................................................. 17

1.9 Related Environmental Documents ..................................................................................... 20

1.9.1 WS Programmatic Environmental Impact Statement (EIS).......................................... 20

1.9.2 Resident Canada Goose EIS................................................................................................... 21

1.9.3 EAs Being Superseded by this Document.......................................................................... 21

Chapter 2 AFFECTED ENVIRONMENT ................................................................................ 22

2.1 Resources Protected.................................................................................................................. 22

2.1.1 Agriculture................................................................................................................................... 22
2.1.2 Human Health and Safety ....................................................................................................... 23

2.1.2.1 Human Safety/Aviation................................................................................................... 23

2.1.2.2 Human Health .................................................................................................................... 24

2.1.3 Damage to Property .................................................................................................................. 25

2.1.3.1 Spread of Landfill Refuse............................................................................................... 26

2.1.4 Protection of Natural Resources............................................................................................ 26

2.1.4.1 Avian Predation on Juvenile Salmonids at Hydroelectric Dams ........................ 26

2.1.4.2 Hatcheries and Juvenile Salmonid Protection .......................................................... 28

2.1.4.3 Economic Value of ESA Listed Salmonids and their Protection........................ 30

2.2 Bird Species in Washington ................................................................................................... 30

2.2.1 Depredation Order Species..................................................................................................... 31

2.2.2 Waterfowl .................................................................................................................................... 31

2.2.6 Passerines..................................................................................................................................... 34

2.2.7 Shorebirds.................................................................................................................................... 34

2.2.8 Raptors.......................................................................................................................................... 35

2.2.9 Introduced and Invasive Species........................................................................................... 35

2.3 T&E Species in Washington.................................................................................................. 35

Chapter 3 ALTERNATIVES AND METHODS..................................................................... 38

3.1 Introduction................................................................................................................................. 38

3.2 Description of Alternatives Analyzed in Detail ............................................................... 38

3.2.1 Alternative 1 – Continue the Current WA WS Bird Damage Management Program, 

Nonlethal Preferred Over Lethal Control (No Action/Preferred Alternative)......... 38

3.2.2 Alternative 2 – Implement All Nonlethal Methods Before Using Lethal Methods 39

3.2.3 Alternative 3 - Technical Assistance BDM Program Only ........................................... 39

3.2.4 Alternative 4 - No WS BDM Program................................................................................ 39

3.3 Alternatives Eliminated from Further Consideration ..................................................... 39

3.3.1 Lethal Methods Only Alternative ......................................................................................... 39

3.3.2 Eradication of Native Bird Species Alternative................................................................ 40

3.3.3 Wildlife Damage Must Be an Accepted Loss Alternative............................................. 40

3.4 BDM Strategies Used by WA WS....................................................................................... 40

3.4.1 Educational Efforts.................................................................................................................... 41

3.4.2 Technical Assistance (TA)...................................................................................................... 41

3.4.3 Operational Bird Damage Management.............................................................................. 41

3.4.3.1 Preventive Bird Damage Management....................................................................... 41
3.4.3.2 Corrective Bird Damage Management ....................................................................... 42

3.4.4 Research and Development .................................................................................................... 42

3.5 Minimization Measures and SOPs for BDM Techniques............................................. 42

Chapter 4 ENVIRONMENTAL CONSEQUENCES ............................................................ 44

4.1 Environmental Consequences................................................................................................ 44

4.1.1 Non-significant Impacts........................................................................................................... 44

4.1.2 Irreversible and Irretrievable Commitments of Resources............................................ 44

4.1.3 Evaluation of Significance of Cumulative and Unavoidable Impacts........................ 44

4.1.3.1 Magnitude of the Impact (size, number, or relative amount of impact)............ 44

4.1.3.2 Duration and Frequency of the Impact ....................................................................... 45

4.1.3.3 Geographic Extent ............................................................................................................ 45

4.2 Issues Analyzed in Detail........................................................................................................ 45

4.3 Issues Not Analyzed in Detail with Rationale .................................................................. 45

4.3.1 WS’ Impact on Biodiversity................................................................................................... 45

4.3.2 Appropriateness of Preparing an EA (Instead of an EIS).............................................. 45

4.3.3 Cost Effectiveness of Bird Damage Management ........................................................... 46

4.3.4 Bird Damage Management Should Be Conducted by Private Nuisance Wildlife 

Control Agents........................................................................................................................... 46

4.3.5 Effects from the Use of Lead Ammunition in Firearms................................................. 46

4.3.6 Perception of Aesthetics.......................................................................................................... 47

4.4 Alternatives Analyzed in Detail............................................................................................ 48

4.4.1 Alternative 1: Continue the Current WS BDM Program, with Nonlethal Preferred 

Over Lethal Control (No Action/Proposed Alternative)................................................ 48

4.4.1.1 Effect of Damage Management Methods on Non-target and ESA-listed 

Species............................................................................................................................... 48

4.4.1.2 Effect of Take on Populations of Target Species .................................................... 50

4.4.1.3 Humaneness of Methods................................................................................................. 66

4.4.1.4 Effectiveness of BDM Program in Washington ...................................................... 68

4.4.2 Alternative 2: Implement All Nonlethal Methods Before Using Lethal Methods.. 68

4.4.2.1 Effects of Methods on Non-target and ESA-listed Species.................................. 68

4.4.2.2 Effect of Methods on Populations of Target Species............................................. 68

4.4.2.3 Humaneness of Methods................................................................................................. 69

4.4.2.4 Effectiveness of BDM Program in Washington ...................................................... 69

4.4.3 Alternative 3: Technical Assistance BDM Program Only ........................................... 69

4.4.3.1 Effects of Methods on Non-target and ESA-listed Species.................................. 69
4.4.3.2 Effects of Methods on Populations of Target Species ........................................... 70

4.4.3.3 Humaneness of Methods................................................................................................. 70

4.4.3.4 Effectiveness of BDM Program in Washington ...................................................... 70

4.4.4 Alternative 4: No WS Program ............................................................................................ 70

4.4.4.1 Effect of Methods on Non-target and ESA-listed Species.................................... 71

4.4.4.2 Effect of Methods on Populations of Target Species............................................. 71

4.4.4.3 Humaneness of Methods................................................................................................. 71

4.4.4.4 Effectiveness of BDM Program in Washington ...................................................... 71

4.5 Cumulative Impacts.................................................................................................................. 72

4.6 Summary...................................................................................................................................... 72

Chapter 5 LIST of PREPARERS, REVIEWERS, and PERSONS CONSULTED....... 74

5.1 Preparers and Reviewers......................................................................................................... 74

5.2 Persons Consulted..................................................................................................................... 74

Literature Cited ...................................................................................................................................... 75

Appendix A Additional Tables and Figures ....................................................................... 83

Appendix B Authorities and Compliance ............................................................................ 87

Appendix C Bird Damage Management Methods............................................................ 92
Acronyms Used in the EA

APHIS Animal and Plant Health Inspection Service 

AVMA American Veterinary Medical Association

BBS Breeding Bird Survey

BDM Bird Damage Management

BGEPA Bald and Golden Eagle Protection Act

BLM Bureau of Land Management

BNA Birds of North America

BOR Bureau of Reclamation

BRN Bird Research Northwest 

CDC Center for Disease Control

CDFG California Department of Fish and Game

CE Categorical Exclusion

CEQ Council on Environmental Quality

CFR Code of Federal Regulations

EA Environmental Assessment

EIS Environmental Impact Statement

EO Executive Order

ESA Endangered Species Act

FAA Federal Aviation Administration

FAR Federal Aviation Regulations

FR Federal Register

FY Fiscal Year (October 1 through September 30)

IWDM Integrated Wildlife Damage Management

MBTA Migratory Bird Treaty Act

MIS Management Information System

MOA Memorandum of Agreement

MOU Memorandum of Understanding

NASS National Agriculture Statistics Service

NEPA National Environmental Policy Act

NHPA National Historic Preservation Act

NMFS National Marine Fisheries Service

NWRC National Wildlife Research Center 

ODFW Oregon Department of Fish and Wildlife

OSHA Occupational Safety and Health Administration

PIT Passive Integrated Transponder

PUD Public Utility District

RCW Revised Code of Washington

RMBO Rocky Mountain Bird Observatory

SLS Sodium Lauryl Sulfate

TA Technical Assistance

T&E Threatened and Endangered
USACE United State Army Corps of Engineers

USAF United States Air Force

USC United States Code

USDA United States Department of Agriculture

USDI United Sates Department of Interior

USFS United State Forest Service

USFWS United States Fish and Wildlife Service

USGS United States Geological Survey

USN United States Navy

WA Washington

WAC Washington Administrative Code

WDFW Washington Department of Fish and Wildlife

WHA Wildlife Hazard Assessment

WHMP Wildlife Hazard Management Plan

WOS Washington Ornithological Society

WS Wildlife Services

WSDOT Washington Department of Transportation
Bird Damage Management in Washington - 8

CHAPTER 1 PURPOSE AND NEED FOR ACTION

1.1 Introduction

Across the United States, wildlife habitat changes as human populations expand and land is 

transformed to meet varying human needs. Human populations and activities often 

compete with the needs of wildlife and inherently increase the potential for conflicts

between wildlife and people. Additionally, some species not only adjust to human 

presence, but thrive well beyond the carrying capacity of what natural habitat would have 

offered. These species, in particular, are often implicated in conflicts between humans and 

wildlife. The U.S. Department of Agriculture (USDA), Animal and Plant Health Inspection 

Service (APHIS), Wildlife Services’ (WS) Final Environmental Impact Statement (EIS) 

(USDA 19971) summarizes the range of values toward wildlife and wildlife damage:

"Wildlife has either positive or negative values, depending on varying human 

perspectives and circumstances . . . Wildlife generally is regarded as providing 

economic, recreational and aesthetic benefits . . . , and the mere knowledge that 

wildlife exists is a positive benefit to many people. However . . . the activities of some 

wildlife may result in economic losses to agriculture and damage to property . . . 

Sensitivity to varying perspectives and values is required to manage the balance 

between human and wildlife needs. In addressing conflicts, wildlife managers must 

consider not only the needs of those directly affected by wildlife damage but a range of 

environmental, sociocultural, and economic considerations as well."

1.1.1 Wildlife Acceptance Capacity

Wildlife acceptance capacity, also known as the cultural carrying capacity, is the limit of 

human tolerance for wildlife or the maximum number of a given species that can 

reasonably coexist with local human populations (Decker and Purdy 1988). Biological 

carrying capacity is the land or habitat’s ability to support healthy populations of 

wildlife without degradation to the species’ health or their environment over an 

extended period of time (Decker and Purdy 1988). These principles are especially 

important because they define public sensitivity to a wildlife species. For any given 

damage situation, there are varying thresholds of tolerance from people affected by 

wildlife and any associated damage. This damage threshold is a factor in determining 

the wildlife acceptance capacity. While an area may have a biological carrying capacity 

that can support larger bird populations, the wildlife acceptance capacity can be 

substantially lower. Once the wildlife acceptance capacity is met or exceeded, people

seek and may begin to implement damage reduction methods to alleviate damage and 

human health or safety threats. As the federal agency authorized by Congress to

respond to wildlife conflicts, WS may, when requested, implement a program to 

alleviate human/wildlife conflicts. As a standard protocol, WS utilizes an adaptive, 

Integrated Wildlife Damage Management (IWDM) program.

 

1 USDA (1997) may be obtained by contacting the USDA, APHIS, WS Operational Support Staff at 4700 River 

Road, Unit 87, Riverdale, MD 20737-1234.
Bird Damage Management in Washington - 9

1.1.2 Integrated Wildlife Damage Management (IWDM)

Wildlife damage management is the alleviation of damage or other problems caused by, 

or related to, the habits of wildlife and recognized as an integral component of wildlife 

management (The Wildlife Society 1992). IWDM is the application of safe and practical 

methods for the prevention and reduction of damage caused by wildlife based on a local 

problem analysis and the informed judgment of trained personnel. IWDM includes 

localized habitat and behavioral modification and/or removal of the offending 

animal(s) through lethal methods. WS uses an adaptive, IWDM approach, commonly 

known as Integrated Pest Management, where a combination of methods may be used 

or recommended to reduce wildlife damage. Wildlife damage management is not based 

on punishing offending animals but is a means to reduce future damage. The imminent 

threat of damage or loss of human or natural resources is often sufficient for individual 

actions to be initiated and the need for damage management is derived from the 

specific threats to resources. WS implements IWDM in accordance with the WS 

Decision Model2 (Slate et al. 1992) to address site specificity, maximize effectiveness, 

and select the most appropriate tool or method for the situation (Figure 1.1). As a 

result of this approach, WS implements the most practical and effective method(s) 

proven to reduce or alleviate bird damage. 

1.1.3 The WS Decision Model

WS’ personnel receive requests for assistance that 

encompass a wide range of damage, problems, species, 

locations, and resources. Each request is unique and 

access to a variety of methods allows personnel to 

formulate a more responsible and successful strategy. 

Implementation of these methods is coordinated 

through the use of the Decision Model, illustrated in 

Figure 1.1, as described in WS’ Programmatic EIS 

(USDA 1997). Once the problem has been identified, 

methods and tools are identified for consideration for 

use in each situation. Methods may be eliminated due 

to legal, administrative, environmental, economic, or 

sociocultural considerations. Once a strategy is 

formulated and the resource manager agrees to the 

plan, methods are employed and results are monitored 

for effectiveness and impacts. Methods may be reevaluated and other selections may be made, or new 

facts may change the initial assessment of the 

problem. Projects are concluded when WS personnel 

are no longer directly involved in management 

activities for a specific problem. Some projects may be 

 

2 The WS Decision Model is not a written process but rather a mental problem solving process similar to 

other professions to determine appropriate management actions to take.
Bird Damage Management in Washington - 10

relatively short term, requiring only technical assistance (TA), while others may be 

ongoing, such as chronic threats from wildlife at airfields. 

1.1.4 Cooperators

WS is authorized to enter into cooperative agreements with federal and state agencies, 

local jurisdictions, individuals, organizations, and institutions to reduce risks from 

injurious/nuisance animal species and those species that are reservoirs for zoonotic 

diseases. WS activities and assistance are contingent upon funding from entities 

cooperating with and/or requesting WS’ services and/or upon appropriations or 

specific authorization from the state or federal government. 

Before WS conducts wildlife damage management activities, Agreements for Control, 

Work Plans, or other comparable documents, must be executed between WS and the 

requester of services or land owner/administrator/agency representative (WS 

Directive 2.2103). WS works on a cost-share basis with cooperators to protect 

resources. Cooperators often pay 100% of the costs associated with wildlife damage 

management. 

WS provides assistance to private and public entities which often depend on WS’ 

expertise in reducing losses caused by wildlife. WS also cooperates with other land and 

wildlife management agencies, when requested and as appropriate, to combine efforts 

to effectively and efficiently resolve wildlife damage problems in compliance with 

applicable federal, state, and local laws and Memoranda of Understanding (MOUs) (WS 

Directive 2.210)

1.2 Bird Damage Management in Washington

Bird damage management (BDM) is the combination of TA and operational damage 

management to reduce or eliminate bird damage, or the threat of damage, to a particular 

resource. TA includes recommendations, guidance, and instruction on how to use BDM 

methods that can be safely and effectively used by cooperators. WS is not responsible for 

the application of methods by cooperators as a result of TA and has Categorically Excluded 

TA from the National Environmental Policy Act (NEPA) [7CFR372.5(c)]. Operational 

damage management is applied by WS personnel for situations where professional 

expertise is needed (e.g., trapping and lethal management). Resource owners requesting 

operational damage management assistance are also encouraged to use nonlethal 

management strategies4 when and where appropriate to help reduce damage and minimize 

lethal take whenever possible (WS Directive 2.101). 

 

3 The WS Policy Manual provides WS personnel guidance in the form of program directives. Information 

contained in the WS Policy Manual and its associated directives has been used throughout this EA, but have 

not been cited in the Literature Cited appendix. WS Directives can be found at: 

http://www.aphis.usda.gov/wildlife_damage/ws_directives.shtml

4 The implementation of nonlethal methods may be a prerequisite to obtaining state or federal wildlife 

permits.
Bird Damage Management in Washington - 11

A range of legal operational damage management methods are available for reducing bird 

damage. These methods fall into two categories: preventive (e.g., habitat modification, 

deterrents, exclusion) and corrective (e.g., harassment and removal). BDM would be 

conducted when requested on public and private lands where an Agreement for Control, or 

other appropriate document, is signed. All BDM would comply with applicable federal, 

state, and local laws, permitting processes and current MOUs, Memorandums of 

Agreements (MOA), or work plans between WS and the various management agencies (WS 

Directive 2.210). 

1.2.1 Permits

All BDM on protected birds is conducted under the appropriate permits issued by the 

United States Fish and Wildlife Service (USFWS) and/or the Washington Department of 

Fish and Wildlife (WDFW). WS receives multiple permits for various aspects of its BDM 

program, as well as working under permits issued to cooperators. Permits include 

those issued for the protection of salmon, protection of human health and safety, 

depredation permits for bird conflicts, scientific permits for disease sampling, and other 

activities to allow resolution of bird damage or potential damage as identified. 

1.3 Purpose of the Environmental Assessment

Washington (WA) WS developed multiple Environmental Assessments (EA) to identify and 

evaluate any impacts of WS’ actions for the protection of human health, safety, and 

property on public and private lands in WA. These involved predatory birds (August 

1997), resident Canada geese (Branta canadensis) (November 1999), non-migratory, feral,

Federal Depredation Order birds (November 2000), migratory birds (October 2001), and 

piscivorous birds (June 2003). Each EA was written as the need for assistance with bird 

damage was requested from private/public individuals/agencies and as the BDM program 

in WA developed. WS’ policy is to review actions relative to each EA on a regular basis to 

determine if new issues have arisen, actions are consistent with the analyses in the EAs, 

and to clearly communicate to the public the analysis of cumulative impacts of WS’ actions. 

Rather than continue analyzing WS’ actions relative to each independent EA, WA WS 

believes it can better communicate with the public and more comprehensibly evaluate its 

impacts, actions, cumulative effects, and whether any new issues have arisen by combining 

each of the above EAs into a single new and updated EA. This EA, Bird Damage 

Management in Washington, is that document.

According to APHIS procedures for implementing NEPA, individual BDM actions 

considered in this analysis may be afforded a Categorical Exclusion (CE) (7 CFR §372.5(c), 

60 Federal Register (FR) 6,000, 6,003, 1995). Recommendations for TA are categorically

excluded through WS’ Programmatic NEPA implementation regulations and guidance. All 

WS BDM in WA would be undertaken according to relevant laws, regulations, policies, 

orders and procedures, including the Endangered Species Act (ESA) (WS Directive 2.210). 

Notice of the availability of this document will be published consistent with the agency’s 

NEPA procedures.
Bird Damage Management in Washington - 12

1.4 Proposed Action

WS proposes to continue an adaptive integrated BDM program in WA for the protection of 

agriculture, property, human health and safety, and natural resources by responding to 

requests for assistance through the implementation of integrated and adaptive BDM 

strategies using the WS Decision Model. Under the proposed action, WS would encourage 

the use of practical, effective, and legal methods, used alone or in combination, to meet the 

needs of requesters to resolve conflicts. In accordance with WS Directive 2.101, preference 

is given to practical and effective nonlethal methods5. Most wildlife damage situations 

require professional expertise, an organized damage management effort, and the use of 

multiple damage management methods to sufficiently resolve them; this will be the task of 

WS personnel who are trained and equipped to handle most damage situations. WS 

personnel use the WS Decision Model to evaluate strategies in the context of their 

availability (legal and administrative) and suitability based on biological and social 

considerations6. Following this evaluation, the method(s) deemed to be practical are 

implemented into a management strategy for the situation. WS’ BDM is coordinated with 

regulatory and wildlife management agencies and serves to provide effective resolution of 

bird damage problems. The protected resource, species, location and type of damage, and 

available biologically sound, efficient, and legal methods will be analyzed in this EA to 

determine a course of action to alleviate each conflict.

WS may respond to requests for assistance with TA or operational BDM (when funding is 

provided). When operational BDM is conducted, IWDM would be implemented. WS 

employees provide TA on a variety of methods that resource owners/managers may use, 

including localized habitat modification and exclusion7. TA can be used to resolve certain 

problems where resource owners can safely and effectively apply methods or where 

funding is not available for WS personnel to conduct operational BDM. Nonlethal methods8

implemented under the Proposed Action could include: harassment, exclusionary devices, 

auditory and visual deterrents, repellents, recommendations for habitat modification, and 

live trapping and translocation. Lethal methods implemented under the Proposed Action 

could include egg addling/oiling/removal, euthanasia following live capture, pesticides, 

and shooting. 

The primary bird species for which WS received requests for assistance and provided the 

greatest extent of BDM assistance, from Fiscal Year (FY) 06 through FY10, is listed in Table 

1.1. WA WS anticipates continuing to conduct lethal and nonlethal BDM for these species 

and will analyze take of these species in detail. WS also provided operational BDM 

assistance on the bird species listed in Appendix A for FY06 through FY10 and anticipates 

 

5 Immediate threats to human health and safety may take precedence over the implementation of nonlethal 

methods and the removal of individual birds may occur concurrently with the implementation of nonlethal 

strategies. 

6 As new information or method(s) become available, they are evaluated and could be integrated into the 

current program/Proposed Action following NEPA compliance.

7 BDM methods that are currently implemented and/or recommended by WS are detailed in Appendix B. 

8 In many situations, the implementation of nonlethal methods such as exclusion-type barriers, habitat 

modification, and repellents would be the responsibility of the requestor to implement.
Bird Damage Management in Washington - 13

continuing to provide minimal assistance with 

these species. This list should not be

considered exhaustive because human/bird 

conflicts may occur anywhere in WA and the 

analysis in this EA anticipates and analyzes for 

that possibility. However, take of any bird 

species will comply with annually issued 

USFWS and/or WDFW permits, federal laws, 

and applicable state laws and regulations. 

1.5 Need for Action

WS has the responsibility to respond when 

assistance is requested (Appendix B: 

Authorities and Compliance). From FY06

through FY10, WA WS assistance was requested 

on 1,079 occasions (Management Information 

Systems (MIS) 2011). These requests covered a 

variety of resources and species and often

included estimates or actual costs of damage. 

For the analyzed time period, WA WS recorded 

approximately $14 million in bird-caused

damages to resources and property in Washington (MIS 2011). The proposed action is 

based on the need for a BDM program to facilitate responses to requests for assistance to 

reduce bird damage or potential damage in WA. 

The sections below provide a description of resources damaged by birds in WA. Detailed 

discussion of damage and environments in WA are provided in Chapter 2: Affected 

Environment.

1.5.1 Agriculture

Nationwide, WS provides assistance to agricultural producers to protect crops from 

wildlife damage. WA has approximately 39,400 agricultural production farms and 

14,800,000 acres in agriculture production, and the total value of all agriculture in WA

is approximately $7.7 billion (National Agriculture Statistics Service (NASS) 2009).

Agriculture, as a whole, (including production, processing, marketing, etc.) accounts for 

approximately 13% of the gross state product (NASS 2010). Field crops, fruit, berry, 

and nut crops, as well as livestock production are all susceptible to damage from birds. 

Bird damage reported to WA WS for the FY06 through FY10 period totaled nearly $1.5 

million and encompassed several types of damage (MIS 2011). These damages pose a 

significant economic threat to individual agricultural producers and may affect 

individuals’ livelihoods. Bird damage may be minimal in some instances, and many 

producers may ignore those damages, but other producers can have more substantial 

damage and these producers generally seek assistance from WS and provide damage 

information. 

Species

Number of TA 

Requests

 pigeons, feral (rock) 683

 gulls, glaucous-winged 680

 geese, canada 652

 starlings, european 650

 crows, american 450

 crows, northwestern 362

 cormorants, double-crested 360

 sparrows, house/english 336

 herons, great blue 307

 gulls, herring 306

 gulls, western 305

 flickers, northern 51

 ducks, mallards 39

 birds, unidentifiable 34

 geese, snow, greater 31

Table 1.1. Species for which TA wa provided 

by WS, FY06-FY10.
Bird Damage Management in Washington - 14

1.5.2 Human Health and Safety Concerns

1.5.2.1 Human Health Concerns

WA WS commonly receives requests for assistance with bird damage caused by the 

accumulation of avian feces. Often, requests from cooperators are prompted by 

warnings from safety officials or agencies for the protection of human health. Birds 

foul buildings, bridges, and other structures with feces and nesting materials and 

are host to many naturally occurring zoonotic diseases which are transmissible to 

humans and pets (Weber 1979). Bird feces contain corrosive acids and are laden 

with bacteria, either of which may endanger human health (e.g., excessive fecal 

matter on handrails, stairs and walkways, ventilation intakes, etc.). For FY06 

through FY10, WA WS recorded approximately $332,000 in bird damages where 

feces caused illness or injury, or resulted in an expense for cleanup. Disease 

transmission may occur when people come in contact with contaminated areas or 

diseased birds. The people at greatest risk of contracting zoonotic diseases are 

those who come into direct contact with bird feces or are exposed to fecescontaminated dust in ventilation systems. 

1.5.2.2 Human Safety Concerns

WA WS responds to requests for assistance regarding bird hazards at airports. The 

need to respond to requests for assistance from airports is based on the potential 

for loss of human life and expensive damage to aircraft. From FY06 through FY010,

the Federal Aviation Administration (FAA) and WS recorded $1.8 million in wildlife 

damage to civil aircraft, the U.S. Air Force (USAF) reported approximately $970,000 

in damages for USAF aircraft, and the U.S. Navy (USN) reported approximately $1 

million in damages to naval aircraft in WA. 

1.5.2.3 Property Damage

Bird damage to property in WA State, as reported to WS, totaled approximately 

$10.5 million for FY06 through FY10. Physical damages to buildings, structures, and 

other property are not only expensive, but can lead to health and safety concerns. 

Bird feces and nesting material can damage vehicles, homes, buildings, aircraft, 

water craft, equipment, bridges, industrial facilities, and other property. Birds 

nesting in utility structures may cause power outages by shorting-out transformers 

and substations (e.g., loss of electricity can threaten human health when medical 

equipment is affected or people cannot heat their homes or get running water). 

1.5.2.4 Protection of Natural Resources

WA WS works with several agencies to protect natural resources and threatened 

and endangered (T&E) species. Agencies include: the U.S. Army Corps of Engineers 

(USACE), USFWS, National Marine Fisheries Service (NMFS), Public Utility Districts 

(PUD’s), WDFW, and others. Migrating T&E salmon and steelhead smolt become 

more susceptible to predation by birds as they pass through dams on their 
Bird Damage Management in Washington - 15

migration to the ocean. Dams locally concentrate their numbers and the currents at 

outfalls can cause them to become temporarily disoriented and remain near the 

surface where they are more vulnerable to predation. Federal agencies, including 

WS, are required to help protect T&E species, and specific regulations and 

monitoring are also in place for hydroelectric facilities to help ensure smolt survival. 

Fish bypasses, “fish friendly” turbines, and many other measures are constructed by 

hydroelectric facilities to protect and enhance salmon and steelhead survival. 

Hydroelectric facilities also work to protect migrating smolt from the opportunistic 

feeding activities of predatory birds. WS assists these facilities and agencies to 

reduce this predation. Other damages to natural resources caused by birds, 

especially waterfowl and gulls, can include damage to watersheds and soil from 

overgrazing, erosion, and the contamination of beaches and waters with fecal 

material. 

WA WS recorded approximately $237,000 in damages to natural resources for the 

analysis period (MIS 2011), but it is not always possible to assign a value to natural 

resources. The USACE presented a breakdown of Juvenile Salmon Economic 

Valuation in USACE (2004) which shows an annual cost of $500 million for salmonid 

restoration programs, with the value of one adult salmon equaling $300. USACE

estimates that it takes 50 juvenile salmon to return one adult, because in part it is 

estimated that up to 40% of some seaward salmon migrations are consumed by 

piscivorous birds. 

1.6 Decisions to be Made

WS is the lead agency for this EA and therefore responsible for the scope, content, and 

decisions made. Based on the scope of this EA, the decisions to be made are:

How can WA WS best respond to the need to reduce bird damage in WA?

What are the environmental effects from implementing various management 

strategies?

Does the proposal have significant enough effects to require an EIS? 

1.7 Scope of the EA

1.7.1 Actions Analyzed

This EA evaluates a proposed BDM program to protect agriculture, human health and 

safety, property, and natural resources in WA. 

1.7.2 Period for which this EA is Valid

This EA will remain valid until WS and other appropriate agencies determine that a new 

need for action is warranted, conditions change, or new alternatives having different 

environmental effects must be analyzed. At that time, this EA would be reviewed,

supplemented or reissued pursuant to NEPA, as appropriate. 
Bird Damage Management in Washington - 16

1.7.3 Site Specificity 

Because the proposed action is to implement an adaptive, integrated BDM program 

throughout WA, it is conceivable that additional damage management efforts may be 

requested. This EA analyzes the effects from existing actions while trying to forecast 

potential needs for assistance, and analyzes the impacts from those potential actions. It 

emphasizes significant issues as they relate to specific areas whenever possible. If 

requests for assistance are obtained that incorporate aspects not analyzed in this EA, 

additional NEPA analysis and compliance would be conducted.

By using the Decision Model (Slate et al. 1992), WS believes it meets the intent of NEPA 

with regard to site-specific analysis and that this is the only practical way for WS to 

comply with NEPA and still be able to accomplish its mission. WS determined that a 

more detailed and more site-specific level of analysis would not substantially improve 

the public’s understanding of the proposal, the analysis, the decision-making process, 

and pursuing a more site-specific and more detailed analysis might even be considered 

inconsistent with NEPA’s emphasis on reducing unnecessary paperwork (Eccleston 

1995). In addition, in terms of considering cumulative impacts, one EA analyzing WS 

BDM affects in WA will allow better monitoring than multiple EA’s covering smaller 

zones within WA.

1.7.4 Resources Not Currently Protected by WS BDM 

The current program operates on a small percentage of the area within WA and 

provides assistance when requested. This EA analyzes effects at the current program 

level and attempts to identify increased program levels should individuals or agencies 

request assistance. Any increase is anticipated to be minimal and within the scope of 

the EA. 

1.7.5 WA Native American Tribes

If Native American Tribes request WS assistance, the methods employed and potential 

effects would be the same as for any private land upon which WS could provide 

services. WS would only use methods discussed and analyzed in this EA and would 

address cultural concerns with tribal representatives at the time an agreement is 

signed. Therefore, this EA covers such actions as requested and implemented. 

Currently, WA WS has no MOUs with Washington Native American Tribes. If WS enters 

into an agreement with a Native American Tribe for BDM, this EA would be reviewed 

and, if appropriate, supplemented to ensure compliance with NEPA. MOUs, agreements 

and NEPA compliance would be conducted, as appropriate, before conducting any BDM 

on tribal lands. 

1.7.6 Public Lands

WS may provide BDM on public lands in WA as requested by the USFWS, U.S. Forest 

Service (USFS), Bureau of Land Management (BLM), USACE, WDFW, or other public 
Bird Damage Management in Washington - 17

land management agency under the appropriate permits and authorizations. The 

strategies and methods employed would be the same on these lands as they would be 

on other lands upon which WS provides BDM. If WA WS were requested to conduct 

BDM on public lands for the protection of resources, WS would consult with the land 

management agency and this EA would cover actions taken. 

1.8 Laws and Regulations

The WS program carries out its federal wildlife damage management responsibility to 

resolve problems that occur when human activity and wildlife are in conflict, while 

recognizing that wildlife are an important public resource greatly valued by the American 

people. The authorities imparted to the Secretary of Agriculture by the Act of March 2, 

1931, as amended, and the Act of December 22, 1987, have been delegated to APHIS, a 

USDA agency. Within APHIS, these authorities have been delegated to the WS program. 

Accordingly, WS’ authorities support and authorize its mission of providing federal 

leadership and expertise to reduce problems caused by injurious and/or nuisance wildlife 

to human health and safety9, to agricultural and other natural resources, including other 

wildlife and T&E wildlife; and minimizing potential wildlife harm or threats. WS’ Policy 

Manual reflects this mission and provides guidance for conducting wildlife damage 

management. 

The current WS program is subject to legal/administrative authorities (e.g., Act of March 2, 

1931, as amended), other federal laws, and applicable state laws and statutes, and takes 

into account the biological, physical, and socio-cultural environment when evaluating BDM 

actions and methods to resolve conflicts. Other federal and state agencies are tasked with 

various aspects in managing public resources, and are integral to the application of IWDM. 

For a more detailed discussion of agencies, laws, and regulations, see Appendix B. Below is 

a brief discussion of agencies and regulations that apply to the analysis. 

Agency Participation in Preparation:

WS consults and cooperates with other federal and state agencies, as appropriate, to ensure 

that all WS activities are carried out in compliance with all applicable federal and state 

laws.

U.S. Army Corps of Engineers. USACE operates select dams along the Columbia and Snake 

Rivers. 

 

9 See www.aphis.usda.gov/ws/mission.html. Examples of APHIS-WS activities include: training of wildlife 

damage management professionals; development and improvement of strategies to reduce losses and threats 

to humans from wildlife; collection, evaluation, and dissemination of management information; cooperative 

wildlife damage management programs; informing and educating the public on how to reduce wildlife 

damage; and providing data and a source for limited-use management materials and equipment, including 

pesticides.
Bird Damage Management in Washington - 18

Bureau of Reclamation (BOR). Founded by the Reclamation Act of 1902, the BOR oversees 

water resource management, including several hydroelectric facilities along the Columbia 

and Snake Rivers in WA. 

United States Fish and Wildlife Service. The USFWS is the primary federal agency 

responsible for conserving, protecting, and enhancing the nation’s fish and wildlife 

resources and their habitats. 

Federal Aviation Administration. The FAA’s authority for managing wildlife hazards at 

airports is based on 14 CFR, Part 139.337. The FAA is the federal agency responsible for 

developing and enforcing air transportation safety regulations and is authorized to reduce 

wildlife hazards at commercial and non-commercial airports. A MOU was developed in 

1998 between the FAA and WS, establishing a cooperative relationship between the two 

agencies to resolve wildlife hazards to aviation. 

National Marine Fisheries Service. NMFS is responsible for ensuring that hydroelectric 

facilities do not compromise the survival of migrating salmon and steelhead under the ESA 

and the Magnuson-Stevens Fishery Conservation and Management Act. 

Oregon Department of Fish and Wildlife (ODFW). ODFW’s mission is to protect and enhance 

Oregon's fish and wildlife and their habitats for use and enjoyment by present and future 

generations.

Washington Department of Fish and Wildlife. WDFW has the commission to “preserve, 

protect, perpetuate, and manage wildlife...” in the state under the Revised Code of WA 

(RCW) 77.04.012.

Washington Department of Transportation (WSDOT). WSDOT’s authority for managing 

transportation in the State is derived from RCW 47.01.011. 

Compliance with Federal Laws, Executive Orders and Regulations

National Environmental Policy Act: All federal actions are subject to NEPA (Public Law 91-

190, 42 U.S.C. 4321 et seq.). WS follows the Council on Environmental Quality (CEQ) 

regulations implementing NEPA (40 CFR 1500 et seq.), USDA (7 CFR 1b), and WS follows 

the APHIS Implementing Guidelines (7 CFR 372) as a part of the decision-making process. 

Endangered Species Act: Under the ESA, all federal agencies are charged with a 

responsibility to conserve T&E species and to utilize their authorities in furtherance of the 

purposes of the ESA (Sec.2(c)). WS conducts Section 7 consultations with the USFWS to 

utilize the expertise of the USFWS to ensure that, "Any action authorized, funded or carried 

out by such an agency . . . is not likely to jeopardize the continued existence of any endangered 

or threatened species . . ." (Sec.7 (a) (2)). WS conducts formal Section 7 Consultations with 

the USFWS at the national level (USDI 1992) and consultations with the USFWS at the local 

level, as appropriate. 

Migratory Bird Treaty Act (MBTA) of 1918 (16 U.S.C. 703-711; 40 Stat. 755), as amended:

The MBTA provides the USFWS regulatory authority to protect species of birds that 
Bird Damage Management in Washington - 19

migrate outside the U.S. The law prohibits any "take" of these species by private entities, 

except as permitted by the USFWS; therefore the USFWS issues permits to reduce bird 

damage (50 CFR 21.41). European starlings (Sturnus vulgaris), feral pigeons (Columba 

livia), house sparrows (Passer domesticus) and domestic/feral birds are not classified as 

protected migratory birds and therefore have no protection under the MBTA. USFWS 

Depredation Permits are also not required for yellow-headed blackbirds (Xanthocephalus 

xanthocephalus), red-winged blackbirds (Agelaius phoeniceus), Brewer’s blackbirds 

(Euphagus cyanocephalus), American, crow (Corvus brachyrhynchos), northwestern crow 

(C. caurinus), fish crows (C. ossifragus), cowbirds (Molothrus spp.), grackles (Quiscalus spp.), 

and magpies (Pica spp.) “found committing or about to commit depredation upon 

ornamental or shade trees, agricultural crops, livestock, or wildlife, or when concentrated 

in such numbers and manner as to constitute a health hazard or other nuisance” (50 CFR 

21.43). One additional exemption to USFWS Depredation Permits is found in 50 CFR 21.46: 

“Landowners, sharecroppers, tenants, or their employees or agents actually engaged in the 

production of nut crops in Washington and Oregon may, without a permit, take scrub jays 

(Aphelocoma coerulescens) and Steller’s jays (Cyamo cittastelleri) when found committing 

or about to commit serious depredations to nut crops on the premises owned or occupied 

by such persons...” This exemption applies only to the Washington counties of Clark, 

Cowlitz and Lewis, and only between August 1 and December 1 of any year. In other 

locations in Washington, for other reasons, or at other times of the year, control of these 

species would be subject to MBTA permitting requirements.

Bald and Golden Eagle Protection Act (BGEPA) (16 U.S.C. §§ 668-668d, June 8, 1940, as 

amended 1959, 1962, 1972, and 1978): The BGEPA prohibits the taking or possession of 

and commerce in bald and golden eagles, with limited exceptions. Take includes pursue, 

shoot, shoot at, poison, wound, kill, capture, trap, collect, molest or disturb. Transport 

includes convey or carry by any means; also deliver or receive for conveyance. 

National Historical Preservation Act (NHPA) of 1966, as amended: The NHPA and its 

implementing regulations (CFR 36, 800) require federal agencies to initiate the section 106 

process if an agency determines that the agency’s actions are undertakings as defined in 

Sec. 800.16(y) and, if so, whether it is a type of activity that has the potential to cause 

effects on historic properties. If the undertaking is a type of activity that does not have the 

potential to cause effects on historic properties, assuming such historic properties were 

present, the agency official has no further obligations under section 106. 

Native American Graves Protection and Repatriation Act: The Native American Graves 

Protection and Repatriation Act requires federal agencies to notify the Secretary of the 

Department that manages the federal lands upon the discovery of Native American cultural 

items on federal or tribal lands. Federal projects would discontinue work until a 

reasonable effort has been made to protect the items and the proper authority has been 

notified.

Occupational Safety and Health Act of 1970: The Occupational Safety and Health Act of 

1970 (OSHA) and its supplementing regulations (29CFR1910) on sanitation standards 

states that "Every enclosed workplace shall be so constructed, equipped, and maintained, 

so far as reasonably practical, as to prevent the entrance or harborage of rodents, insects, 
Bird Damage Management in Washington - 20

and other vermin. A continuing and effective extermination program shall be instituted 

where their presence is detected." This standard includes birds that may cause safety and 

health concerns at workplaces.

Environmental Justice and Executive Order (EO) 12898 - Federal Actions to Address 

Environmental Justice in Minority Populations and Low-Income Populations: 

Environmental Justice has been defined as the pursuit of equal justice and equal protection 

under the law for all environmental statutes and regulations without discrimination based 

on race, ethnicity, or socioeconomic status. The nature of WS’ BDM activities is such that 

they do not have much, if any, potential to result in disproportionate environmental effects 

on minority or low-income populations. Therefore, no such adverse or disproportionate 

environmental impacts to such persons or populations are expected.

Executive Order 13045 - Protection of Children from Environmental Health and Safety Risks: 

Children may suffer disproportionately from environmental health and safety risks, 

including their developmental physical and mental status, for many reasons. Based on the 

Risk Assessment (USDA 1997, Appendix P), WS concluded that when program chemicals 

and non-chemical methods are used following label directions, normally accepted safety 

practices, and WS standard operating procedures, such use has negligible impacts on the 

environment or on human health and safety, which includes the health and safety of 

children.

Executive Order 13112 - Invasive Species: Authorized by former President Clinton, EO 

13112 establishes guidance to federal agencies to prevent the introduction of invasive 

species and provide for their control and to minimize the economic, ecological, and human 

health impacts that invasive species cause. The EO, in part, states that each federal agency 

whose actions may affect the status of invasive species shall, to the extent practicable and 

permitted by law: 1) reduce invasion of exotic species and the associated damages, 2) 

monitor invasive species populations and provide for restoration of native species and 

habitats, 3) conduct research on invasive species and develop technologies to prevent 

introduction, and 4) provide for environmentally sound control and promote public 

education on invasive species. 

Executive Order 13186 and MOU between USFWS and WS: EO 13186 directs federal 

agencies to protect migratory birds and strengthen migratory bird conservation by 

identifying and implementing strategies that promote conservation and minimize the take 

of migratory birds through enhanced collaboration between WS and the USFWS, in 

coordination with state, tribal, and local governments. A national-level MOU between the 

USFWS and WS has been drafted to facilitate the implementation of EO 13186.

1.9 Related Environmental Documents

1.9.1 WS Programmatic Environmental Impact Statement (EIS) 

WS issued a final EIS (USDA 1997) and Record of Decision on the USDA APHIS WS 

nationwide program. The final EIS (USDA 1997) discussed BDM at the nationwide level 

and concluded that nationwide the WS program did not impact bird populations. 

Pertinent portions of the EIS are incorporated by reference in this EA.
Bird Damage Management in Washington - 21

1.9.2 Resident Canada Goose EIS

The USFWS Resident Canada Goose EIS was prepared in cooperation with WS in 

response to growing impacts from the overabundant populations of resident Canada 

geese. Alternatives were fully described and evaluated in the Final EIS, and a Record of 

Decision (ROD) and Final Rule published by the USFWS on August 10, 2006 (Federal 

Register Vol. 71, No. 154: 45964- 45993). In accordance with the CEQ regulations (40 

CFR 1506.3), WS adopted the Final EIS to support program decisions for involvement in 

resident Canada geese damage reductions. On August 10, 2006, WS issued a ROD on the 

Resident Canada Goose Management EIS, prepared in cooperation with USFWS. As 

described in the ROD, WS will take action under the rules, depredation orders, and 

permits, in coordination with USFWS and WDFW to reduce resident Canada goose 

damage in Washington. Pertinent portions of the EIS are incorporated by reference in 

this EA. 

1.9.3 EAs Being Superseded by this Document

The following EAs will be superseded by this document:

1) Bird Damage Management (BDM) in the State of Washington. [As associated with 

“depredating” nonnative (invasive) birds, feral domestic waterfowl, nonmigratory 

birds, and those migratory birds as provided for in 50 Code of Federal Regulations 

(CFR)] (November 2000). Pertinent portions of the EA are incorporated by reference in 

this EA. 

2) The Management of Damage Caused by Migratory Birds in the State of Washington 

(MIGRATORY BIRD) EA (October 2001). Pertinent portions of the EA are incorporated 

by reference in this EA. 

3) The Piscivorous Bird EA (June 2003). Pertinent portions of the EA are incorporated 

by reference in this EA. 

The management of predatory birds under the Predator Damage Management in 

Washington EA (May 2010) will be analyzed under this document. 
Bird Damage Management in Washington - 22

Chapter 2 AFFECTED ENVIRONMENT

The affected environment is within the geographic boundaries of WA State and the 

Columbia River, including those areas of Oregon shoreline proximate to USACE dams. WA

State contains 66,582 square miles of land and 4,721 square miles of water. Under the 

current program, WS provides assistance on 1,638 square miles, however projects may 

occur anywhere in the designated area, where requested (See Section 1.1.4). 

2.1 Resources Protected 

2.1.1 Agriculture

Nationally, more than half of all farmers and ranchers experience damage from wildlife 

each year. Wildlife damage to apples, blueberries, and grapes has been estimated at 

$40 million annually (APHIS 2004). WA is a major producer of several crops, including 

more than half of the nation’s apple crop (NASS 2010) as well as other soft fruits (e.g., 

berries, cherries, peaches, grapes). WA’s top agricultural products include field crops, 

fruits and nuts, and livestock and their products (NASS 2009). 

Producers in WA face several kinds of bird-caused damages; those most commonly 

encountered by WA WS are consumption and contamination of crops. European 

starlings, house finches (Carpodacus mexicanus), English sparrows, American robins

(Turdus migratorius), and brown-headed cowbirds (Molothrus ater) are often 

responsible for damages to fruit crops, such as apples, cherries, grapes, and blueberries. 

Waterfowl, turkeys (Meleagris spp.), and other game birds are often responsible for 

pulling seedling crops. From FY06 throughFY10, starling damages to cherries totaled 

more than $262,000 (MIS 2011). Passerine species such as cedar waxwings 

(Bombycilla cedrorum) and American robins have been responsible for damages to 

blueberries and cherries. Grain crops are especially vulnerable to damage from birds 

because the grains are exposed through the entire growing season (USDA 2003a). 

Canada geese, starlings, cowbirds, English sparrows, and feral pigeons caused more 

than $300,000 in damages to grains and pasture crops in WA from FY06 through FY10 

(MIS 2011). 

In 2008, livestock production was the third largest agricultural commodity in WA. 

Many bird species find livestock production facilities attractive food sources because of 

the protein additives in the feed (Gorenzel et al. 1994). Blackbirds, starlings, English 

sparrows, feral pigeons, and crows often consume or contaminate feed at cattle feeding 

facilities and dairies. Flocks of up to 250,000 and more starlings have been reported at 

feedlots in WA (MIS 2011). Large flocks of birds also carry species of mites that may be 

introduced into poultry houses (Kern 1997). Black-billed magpies (Pica hudsonia) and 

common ravens (Corvus corax) have also been known to destroy eggs, peck out the eyes 

of lambs, and are responsible for newborn livestock mortality (Hygnstrom et al. 1994, 

Larson and Dietrich 1970). Ravens have been reported damaging silage bags, resulting 

in the spoilage of feed. 
Bird Damage Management in Washington - 23

Species Value

 starlings, european $387,628

 cormorants, double-crested $240,002

 ducks, merganser common $200,000

 geese, snow, greater $185,000

 geese, canada $142,675

 finches, house $90,813

 gulls, glaucous-winged $42,125

 cranes, sandhill $27,000

 cowbirds, brown-headed $26,500

 robins, american $24,000

 pigeons, feral (rock) $21,320

 crows, american $12,920

 sparrows, house/english $11,620

 blackbirds, red-winged $10,000

 ducks, wigeon, american $10,000

 geese, snow, lesser $10,000

 herons, great blue $5,006

 ducks, bufflehead $5,000

 ducks, merganser, hooded $5,000

Table 2.1. Bird damage to agriculture, recorded by 

WS, FY06-FY10.

WA’s aquaculture industry produces 

a large array of products including 

shellfish, trout, salmon, and aquatic 

plants, such as seaweed. In 2007, 

WA aquaculture producers reported 

$163 million in sales across 355 

farms in the state. Piscivorous birds 

consume, injure, and stress 

aquaculture crops by feeding and 

loafing at the facilities. Industry 

wide, costs associated with bird 

damage and bird damage prevention 

exceed $17 million annually (USDA 

2003a) 

Birds are also vectors for diseases 

and parasites that negatively impact 

fish, shellfish, and aquatic plants 

(Gorenzel et al. 1994). Merganser 

(Mergus spp.) and cormorant 

(Phalacrocorax spp.) damage to 

salmonids produced for aquaculture 

purposes (not T&E population 

enhancement) for FY06 through 

FY10 totaled more than $469,000 and damages by other species to other aquaculture 

resources totaled about $100,000. Canada geese have been reported damaging oyster 

beds through feces contamination. Great blue herons (Ardea herodias) and certain 

species of waterfowl are common predators at trout hatcheries, and injure and stress 

trout. 

These examples are not inclusive of all type of damages that occur to agriculture in WA, 

just those reported to WS. Damages are only reported to WS when the producers 

contact WS for assistance, therefore WS is not able to document the majority of losses. 

Table 2.1 highlights a list of species and damage amounts reported to WS.

2.1.2 Human Health and Safety

2.1.2.1 Human Safety/Aviation

WS provided assistance to 39 airports in WA and continues to conduct BDM at 

several of these airports. According to the FAA, 92% of birdstrikes occur at or 

below 3,000 feet above ground level (AGL) and 72% occur at or below 500 feet AGL, 

making airports and the immediate vicinity the primary areas for BDM in order to 

reduce wildlife attractants and hazards. Airports encompass large areas of land and 

are often in close proximity to landfills, wetlands, and other habitats that attract a 

variety of bird species. Many of these species feed, loaf, or roost near airport 

runways, and pose a threat to air travelers, pilots, crews, and people on the ground. 
Bird Damage Management in Washington - 24

WA WS actively promotes responsible management of airfields and surrounding 

areas in an effort to prevent conflicts between birds and aviation. 

Many bird species enter airport operation areas, and due to their body-size and/or 

tendency to flock, may cause substantial damage or loss of human life when 

colliding with aircraft. Birds commonly encountered in airport environments in WA 

include: waterfowl (Family Anatidae), gulls (Family Laridae), corvids (Family

Corvidae), raptors (Family Accipitridae), shorebirds (Families Charadriidae and 

Scolopacidae)

10, European starlings, and feral pigeons. A steady growth in the 

populations of some large flocking birds, their successful adaptation to urban 

landscapes, and increased aircraft operations have contributed to a significant 

increase in birdstrikes (Dolbeer and Seubert 2006).

Globally, wildlife strikes have killed at least 276 people and destroyed more than 

210 aircraft since 1988 (Richardson and West 2000, Thorpe 2010, Dolbeer, 

unpublished data). Since 1990, there were 167 strikes reported involving U.S. civil 

and commercial aircraft that resulted in 209 human injuries. Waterfowl, vultures

(Coragyps atratus, Cathartes aura) and deer (Odocoileus spp.) caused 82 of these 

strikes (Dolbeer et al. 2009). In 1995, a military jet taking off at Elmendorf Air Force 

Base in AK crashed on departure after striking a flock of Canada geese on the 

runway. All 24 crew members were killed and the $180 million aircraft was 

destroyed. The “forced landing” of US Airways Flight 1549 in the Hudson River in 

early 2009, after the ingestion of Canada geese into both engines, endangered the 

lives of the passengers and crew and destroyed the aircraft. 

Nationally, birdstrikes cause an estimated $650 million damage to aviation annually 

(Begier, unpublished data). According to FAA records, 603 wildlife strikes to civil 

aircraft were reported in WA from FY06 through FY09, resulting in $1.5 million in 

damage and lost revenue (FAA 2010). However, it is estimated that only 25 to 39% 

of all birdstrikes are reported (Dolbeer et al. 1995, Linnell et al. 1996, Linnell et al. 

1999, Dolbeer 2009). Consequently, the number of birdstrikes in WA is most likely 

much higher than records indicate. 

2.1.2.2 Human Health11

Protection of human health is an important aspect of BDM in WA. The primary risks 

to human health posed by birds are zoonotic diseases. Zoonotic diseases are 

infectious animal diseases that are transmissible to humans. Examples of pathogens 

that cause these diseases are bacteria, fungi, and viruses. 

 

10 The collision of an aircraft with birds is a serious concern at airports throughout WA and may involve 

many species, including some that may not be analyzed in this EA. Take for species that cause a risk to human 

health is authorized under USFWS Depredation Permit. 

11 OSHA regulates sanitation standards in the workplace through 29 CFR 1910.141(a) (5). Fines may be 

relatively high for failures to abate hazards associated with bird droppings. For example, OSHA fined a 

Hoboken, NJ manufacturing company $673,400 for failing to abate hazards associated with “severe 

accumulations of pigeon droppings” (Mansdorf 1999). Clean up and removal of large amounts feces can be a 

precarious task that must be conducted correctly to prevent making infectious particles airborne. 
Bird Damage Management in Washington - 25

Many zoonotic diseases or their pathogens have been identified in feral pigeons, 

European starlings, house sparrows, and various waterfowl species, as well as in 

and other migratory bird species (Weber 1979). The primary zoonotic diseases of 

birds in WA include salmonellosis, chlamydiosis, histoplasmosis, Newcastle disease, 

West Nile virus, and avian influenza. Salmonellosis, chlamydiosis, West Nile virus, 

and highly pathogenic avian influenza are reportable diseases. 

Accumulations of bird feces and direct contact are the two most likely ways that 

wild birds can contribute to the risk of human exposure to salmonellosis, 

chlamydiosis, histoplasmosis, Newcastle disease, and avian influenza. The role of 

wild birds in the transmission of the West Nile virus pathogen is different, with 

birds acting as a reservoir host for the virus that is transmitted by mosquito vector 

from bird to human. While wild birds can play a role in the transmission of zoonotic 

pathogens, the ability of the pathogen to actually cause illness in a human varies 

with the virulence of the pathogen, the amount of exposure an individual 

experiences, and the route of infection. 

The Centers for Disease Control (CDC)

(www.cdc.gov/ncezid) and the United 

States Geological Survey (USGS) National 

Wildlife Health Center 

(www.nwhc.usgs.gov) provide additional 

specific information about bird-related 

zoonotic diseases and their potential risks. 

2.1.3 Damage to Property

Increased urbanization has changed and, in 

most cases, lead to a reduction in native 

wildlife habitat. As wildlife populations 

continue to expand, conflicts between humans 

and wildlife will continue to increase (USDA 

2004). Nationally, birds cause millions of 

dollars in damage each year to homes, boats 

and marinas, aircraft, parks, equipment, 

machinery, industrial facilities, roads and 

bridges, parks, and other resources. Table 2.2

highlights damages by species as reported to 

and/or verified by WS in WA. Corrosion

damage to metal structures and painted 

finishes (e.g., bridges) can occur because of 

uric acid from bird droppings. Utility 

companies frequently have problems with 

birds and other animals causing power 

outages by shorting out transformers and 

substations and disrupting communications. 

Species Value

 gulls, glaucous-winged $3,828,190

 terns, caspian $1,743,100

 starlings, european $1,727,825

 pigeons, feral (rock) $1,365,239

 cormorants, double-crested $628,900

 geese, canada $176,150

 cormorants, pelagic $140,600

 crows, american $123,166

 gulls, california $112,960

 flickers, northern $104,050

 gulls, ring-billed $103,750

 gulls, western $76,400

 sparrows, house/english $65,459

 gulls, herring $49,850

 ducks, wigeon, american $46,900

 gulls, mew $25,300

 parakeets, monk $24,300

 blackbirds, brewer`s $24,200

 crows, northwestern $22,500

 birds, unidentifiable $17,000

 ducks, mallards $14,205

 ducks, teal, green-winged $12,400

 ducks, ring-necked $11,900

 hawks, red-tailed $11,900

 blackbirds, red-winged $10,400

 cowbirds, brown-headed $7,300

 gulls, glaucous $7,200

 ravens, common $6,700

Table 2.2 Bird damage to property, recorded by 

WS., FY06-FY10.
Bird Damage Management in Washington - 26

The removal of bird feces and nest material, in conjunction with the reduction in paint 

life caused by uric acid, increases maintenance costs. 

Vermeer et al. (1988) noted that a $350,000 roof was estimated to last only half as long 

as originally credited because of chemical erosion caused by defecation and water 

damage resulting from the blockage of drainage pipes by feathers and nest material of 

gulls. From FY06 through FY10, WA WS recorded approximately $7.7 million in bird 

feces damage and prevention costs.

2.1.3.1 Spread of Landfill Refuse

Landfills can be an unintended source of food for gulls, corvids, starlings, and other 

scavenging birds. Birds often transport trash from landfills to surrounding areas, 

spreading refuse and disease (Butterfield et al. 1983). Birds at landfills and 

associated urban nesting have led to an increase in conflicts with humans (Verbeek 

1977, Bradley 1980, Burger 1981, Patton 1988, Belant and Dolbeer 1993). In 2000, 

a landfill in King County, Washington settled a $16.5 million lawsuit with neighbors 

over odor, noise, vibration, and bird problems (Seattle Post-Intelligencer 2000). 

Birds at landfills also defecate on buildings and equipment, risking the health of 

landfill employees through contact with fecal matter and contaminants from the 

landfill carried by the birds. Landfills and transfer stations in WA are required to 

conduct activities to reduce the potential for bird damage (Washington 

Administrative Code [WAC] 173-351-200). In some cases these facilities request 

assistance from WS. 

WS currently assists landfills in WA to prevent the spread of refuse and disease by 

birds, and also with birdstrike hazards association with airports from the same 

birds. Landfills and transfer stations are often positioned in close proximity to 

airfields, and the movement of birds to and from these facilities is often hazardous 

to aviation. Species most commonly observed at landfills include gulls, starlings, 

crows, blackbirds, and ravens (MIS 2010). WS assists transfer stations with facility 

design to minimize bird access to refuse, and may further assist with operational 

BDM should facility design not be adequate to mitigate risks to human health. 

2.1.4 Protection of Natural Resources

WA WS cooperates with public, regulatory, and land management agencies for the 

protection of natural resources. Non-native and native birds may compete with 

sensitive or less prolific wildlife species and may compete with native species for 

nesting and foraging resources. The primary example of natural resource conflicts in 

WA is piscivorous birds depredating on federal and state listed salmonids. 

2.1.4.1 Avian Predation on Juvenile Salmonids at Hydroelectric Dams

WS currently protects juvenile T&E salmonids from avian predators, primarily gulls 

and terns at Columbia and Snake River dams, where they are artificially susceptible 

to predation by avian predators. Federal regulatory agencies set levels of juvenile 

salmonid passage standards that dams must achieve. WS works cooperatively with 

state and federal resource management agencies, including WDFW, ODFW, USFWS, 
Bird Damage Management in Washington - 27

NMFS, USACE, and PUDs to develop and implement an adaptive and integrated 

program to reduce avian predation at hydroelectric facilities. Hydroelectric 

development changed the Columbia River basin beginning in 1933 from mostly freeflowing rivers to a series of dams and impoundments by 1975 (Gray and Rondorf 

1986, Raymond 1988). 

Reservoirs that formed behind dams and dredge spoil deposition created islands 

that are conducive to piscivorous bird colonization (NMFS 2000). Under the ESA, 

hydroelectric developments on the Columbia and Snake Rivers must be managed to 

ensure the continued existence of ESA-listed species. Juvenile salmonids commonly 

experience a number of stressful events or conditions during their seaward 

migration. Most of these events occur serially and can have cumulative effects, such

when juvenile salmon pass through dams and enter predator-inhabited tailrace 

areas (USACE 2004). Because dam passage is a stressful event, there is concern that 

juvenile salmon passing through dams would not be able to cope with subsequent 

stressors, such as predators (Mesa 1994). 

The major causes of mortality of migrating juvenile salmonids in the Columbia River 

basin were identified as passage through the turbines, total dissolved gas 

supersaturated water due to spill, migration delays, fish disease, and predation by 

birds and fishes in the reservoir, forebay, and tailrace (as cited in USDA 2003b). 

Piscivorous birds often feed in areas of high fish density (Eriksson 1985, Safina and 

Burger 1985; Kennedy and Greer 1998; Blackwell et al. 1997; Derby and Lovvorn 

1997) and attract other birds to feeding areas. Hydroelectric dams act as 

bottlenecks for juvenile salmonid migration and can injure and disorient smolt, 

increasing their vulnerability to avian predators (ODFW 1998). Piscivorous birds 

aggregate below hydroelectric dams in spring and summer and feed on emigrating 

juvenile salmonids. Between 1998 and 2008, avian predators consumed between 

4% and 21% of the juvenile salmonids migrating downriver annually (Muir et al. 

2009). 

WS’ assistance is often requested to augment other T&E protection measures. PUD’s

that own and manage hydroelectric facilities, along with the USACE, use many tools 

to ensure fish passage through the dam meets requirements established by NMFS. 

Hundreds of millions of dollars have been spent to increase salmon survival through 

the 13 hydroelectric facilities along the Columbia and Snake Rivers in Washington

(e.g., approximately 1⁄3 of the Grant County PUD’s entire annual budget goes to 

fisheries improvements). These expenditures include the installation new fishfriendly turbines in two dams, research for the design and the installation of fish 

bypass structures, the installation of wire grid exclusion devices, and assistance 

from WS to deter avian predators. A wide variety of tools are implemented to 

exclude or otherwise nonlethally harass avian predators prior to taking lethal 

action. Fish friendly turbines cost approximately $10M each, while the study to 

design a fish bypass structures is estimated to cost $5-7M. Chelan County PUD has 

implemented a fish bypass structure, turbine modification, wire grids, perch 

deterrents, and auditory harassment, as well as lethal management to reinforce 
Bird Damage Management in Washington - 28

nonlethal methods. The Public Power Council (online) reports that more than $5 

million was spent on research and management programs to reduce avian predation 

at USACE dams in 2009.

In addition to the research and installation of fish passage devices, hydroelectric 

facilities fund WS to reduce avian predation of juvenile salmonids. WS conducts 

operational BDM at hydroelectric facilities to alleviate the predation of salmonid 

smolt by avian predators. WS operational activities at dams include the installation 

of nonlethal wire arrays to deter birds from foraging in the tailrace, the harassment 

of birds that feed on smolt in the tailraces, and shooting to reinforce nonlethal 

methods. Wire arrays are constructed over the tailrace and restrict avian predators 

from accessing the water and salmonids (Figure 2.1). The application of wire arrays 

and designs at dams are continually adapted and updated to meet changing needs 

based on dam structure, spill patterns, bird foraging activity, etc. Harassment of 

avian predators is accomplished by pyrotechnics launched from the shoreline, dam 

structures, and boats to provide thorough coverage of the tailrace. If harassment is 

not effective in preventing predation, shooting is used to reinforce nonlethal 

methods; shooting is not used to manage or reduce populations. Nonlethal 

harassment comprised more than 98% of WS BDM activities at dams. BDM 

programs only occur during seasonal smolt passage specific to each facility and

generally within 1,000 feet downstream from the dam and 500 feet upstream from 

the dam, as defined by USFWS permits. 

2.1.4.2 Hatcheries and Juvenile Salmonid Protection

In 1938, Congress passed the Mitchell Act to provide for the conservation of 

anadromous fishery resources (salmon and steelhead). The Mitchell Act Program is 

managed under the ESA and is undergoing changes to preserve genetic resources. 

WDFW operates 91 hatchery facilities, of which 69 produce salmon and/or 

steelhead while the other 22 raise trout and other game fish. Thirty-five tribal 

hatcheries and 12 federal hatcheries also contribute to the statewide salmon 

harvest, which contributed more than $1 billion to Washington’s economy in 2000. 

These hatcheries are an essential tool in the conservation of native, listed salmonids. 

Hatchery-raised juvenile smolt are used to strengthen ESA-listed species recovery 

efforts and supplement tribal, recreational, and commercial harvest (NMFS et al. 

1998, Waples 1999). The open-water areas and large concentrations of fish at 

hatcheries are natural attractants to many piscivorous birds (Gorenzel et al. 1994). 

Birds that normally migrate have been observed to remain at aquaculture facilities 

year round. Proximity to roosting areas often makes aquaculture facilities more 

attractive to piscivorous birds. Price and Nickum (1995) outlined four categories of 

bird problems that may occur at hatcheries: 

1. Direct predation – smolt are eaten or die as a result of wounds from attempted 

predation. 
Bird Damage Management in Washington - 29

2. Interference with artificial feeding - the smolt are stressed by the presence of 

avian predators and go off their feed, or the birds compete directly with smolt for 

their food. 

3. Spread of disease/continuation of disease outbreaks - pond to pond transmission 

of disease and parasites where smolt may also be stressed are more susceptible to 

disease. 

4. Disturbance during winter in areas where ponds do not freeze-over leading to

stress and competition. 

Application of grid-wire systems and harassment may be recommended or 

implemented by WS in these situations. Lethal reinforcement may be necessary to 

maintain efficacy of nonlethal methods, and is not a primary management measure. 

Figure 2.1. Illustration of Wire Array at Wanapum Dam for the protection of Salmonid Smolt. 
Bird Damage Management in Washington - 30

2.1.4.3 Economic Value of ESA Listed Salmonids and their Protection

The value of ESA-listed juvenile salmonids lost specifically to predation is not 

presented in this EA because juvenile salmonid values12 and total avian predation on 

smolt are not well established. Engeman et al. (2002) reviewed various methods for 

applying monetary valuations for ESA-listed species, but did not apply these to 

salmonids. The economic damage resulting from the predation of juvenile 

salmonids could be represented by the costs associated with the implementation of 

mitigation measures and the cost of each juvenile lost to avian predation. The 

USACE (2004) provided one of the only estimates of expenses associated with 

salmonid valuations (Table 2.3); however, these are not applicable to all 

hydroelectric facilities and salmon species. 

The price of raising a smolt at a hatchery does not take into account the full value of 

juvenile salmonids, particularly those species listed under the ESA. Many of the 

hatchery smolt are produced specifically to supplement natural production, uphold 

Tribal Treaty obligations, and directly assist in the recovery of ESA-listed species 

(WDFW 2002, letter to WS). The application of monetary valuations to ESA-listed 

species is neither straight-forward nor precise (Engeman et al. 2002). 

2.2 Bird Species in Washington

According to the Washington Ornithological Society (WOS), there are 493 bird species in 

Washington (WOS 2008). Four of these species are listed as federally threatened or 

endangered; the marbled murrelet (Brachyramphus marmoratus), spotted owl (Strix 

occidentalis), western snowy plover (Charadrius nivosus), and short-tailed albatross

(Phoebastria albatrus). WA WS has reviewed those listings and determined that the 

Proposed Action will have “no effect” on those species, based on the geographical 

separation of their habitat from WS activities. For the purposes of the EA, WS has divided 

the species presented into functional groups to help summarize significant biological 

factors for the analysis. 

 

12 In the case of T&E species, their value has been judged “incalculable” (Tennessee Valley Authority vs Hill, 

US Supreme Court 1978), making it more difficult to specifically quantify the cost and cost effectiveness of 

efforts to restore or protect these species. 

Table 2.3. Juvenile Salmonid Economic Valuation

Description Estimated Data

Average cost per year for salmonid restoration program $500 million

Anadromous adults recorded at Bonneville in 2001 4.4 million

Cost of Restoration efforts per adult $114

Local economic value of one adult (in 1998 dollars) $186

Total value of one adult $300

Number of Bonneville smolt required to produce one adult 

salmonid (average 2% smolt to adult return rate)

50

Average value of a juvenile salmonid individual $6
Bird Damage Management in Washington - 31

2.2.1 Depredation Order Species

CFR 50 subpart D allows the take of depredating or otherwise injurious birds under 

specific guidance within each Depredation Order. 50 CFR 21.43 allows the control of 

yellow-headed, red-winged, and Brewer’s blackbirds, American, northwestern, and fish 

crows, cowbirds, grackles, and magpies without federal permit when they are “found 

committing or about to commit depredations upon ornamental or shade trees, 

agricultural crops, livestock, or wildlife, or when concentrated in such numbers and 

manner as to constitute a health hazard or other nuisance”. WS may conduct BDM 

under depredation orders and will responsibly apply BDM methods, as described in this 

document, to alleviate damage situations or situations where there is a threat of 

damage. Depredation Order species encountered in damage situations in WA include 

Brewer’s, red-winged, and yellow-headed blackbirds, brown-headed cowbirds,

American and northwestern crows, Steller’s jays, scrub jays, and black-billed magpies. 

2.2.2 Waterfowl

Waterfowl (i.e., ducks, geese, and swans) are monitored and managed by WDFW and 

USFWS. While conflicts with waterfowl are often addressed through hunting 

opportunities, urban conflict generally requires alternative approaches. Waterfowl are 

involved in damage situations in all of the resource categories analyzed in this 

document. Waterfowl are most commonly implicated in damage situations at airports 

where they present a significant threat to aviation due to their size and flocking 

tendencies. Additional types of damage that waterfowl cause include consumption and

contamination of crops, fecal contamination in urban environments, transmission of 

diseases, and damage to turf and flowers. 

2.2.3 Gulls 

Gulls commonly nest and loaf on rooftops, equipment, piers, islands, and rocky 

outcroppings (Butterfield et al. 1983, Monaghan and Coulson 1977, Conover 1983; 

Winkler 1996, Pierotti and Good 1994, Ryder 1993). When found in urban 

environments, nesting groups and colonies negatively impact commercial and private 

structures and human health and safety. OSHA considers bird droppings in the work 

place hazardous [29CFR 1910.141 (a)(5)] and County Health Departments regularly 

monitor landfills, transfer stations, and other facilities to ensure they are not allowing 

gulls or other hazardous wildlife to congregate in a manner that could lead to health 

risks for employees and the public. Landfills have even been suggested as contributing 

to increases in gull populations (Verbeek 1977, Patton 1988, Belant and Dolbeer 1993). 

Regulations mandate that landfills prevent or control potential vectors, such as gulls 

(40 CFR 258.22, WAC 173-351-200). In addition to health risks from groups and 

colonies of nesting gulls; nests, feces, and material brought to feed nestlings (e.g., fish, 

chicken bones, garbage, etc.) cause damage to the structural integrity of rooftops, 

bridges, and buildings. Structures and property at marinas, docks, shipyards, and 

utilities are damaged through these activities which can also be aesthetically 

displeasing.
Bird Damage Management in Washington - 32

Gulls can also negatively impact natural resources through habitat degradation, 

competition with other wildlife, and through direct depredation on natural resources. 

Habitat degradation occurs when large concentrations of gulls in a localized area 

negatively impact characteristics of the surrounding habitat that can adversely affect 

other wildlife species. Competition can occur when two species compete (usually to the 

detriment of one species) for available resources, such as food or nesting sites. Direct 

depredation occurs when predatory gull species feed on other wildlife species which 

can negatively influence those species’ populations, especially when depredation occurs 

on T&E species. Locations with naturally occurring fish populations often attract gulls, 

and fish hatcheries are frequently constructed near naturally occurring concentrations 

of fish (Schaeffer 1992). Gulls cause damage at hatcheries and aquaculture facilities by 

feeding on and stressing broodstock and juvenile fish. Dams act as bottlenecks for 

juvenile salmonid migration and create currents, backflows, and upwellings where gulls 

may depredate vulnerable T&E salmonid smolt. Section 4.4.1.2.2 provides a detailed 

discussion of gull damages to T&E salmonids at dams in WA.

Gulls also often feed and loaf in airport environments where they present a significant 

birdstrike (bird-aircraft collision) risk. Gulls are the most frequently struck birds in WA 

(FAA 2010). 

Gulls cause damage at livestock feeding facilities by congregating in large numbers to 

consume livestock feed. In addition to the feed consumed, such feeding strategies may 

present disease threats to livestock as well. Williams et al. (1977) and Johnston et al. 

(1979) reported that gulls can transmit salmonella to livestock through droppings and 

contaminated drinking water. Gulls also cause damage by defecating on equipment and 

other structures, which can accelerate corrosion of metal components and is generally 

considered an unsightly nuisance and potential health hazard for the feedlot operators 

and their personnel. 

Although gulls do not generally feed on agricultural crops, they do cause damage. 

California gulls (Larus californicus) and ring-billed gulls (L. delawarensis) are known to 

feed on ripening cherries in orchards. In addition, there may be the threat of bacterial 

contamination of fruit or vegetable crops due to accumulation of droppings, particularly 

if gulls have recently fed or loafed at landfills or sewage treatment plants. In 

agricultural settings, there may be risk to the gulls themselves, through contact with 

agricultural chemicals. 

Research has shown that gulls carry various species of bacteria such as Bacillus sp., 

Clostridium sp., Campylobacter spp., Escherichia coli, Listeria spp., and Salmonella spp. 

(MacDonald and Brown 1974, Fenlon 1981, Butterfield et al. 1983, Monaghan et al. 

1985, Norton 1986, Vauk-Hentzelt et al. 1987, Quessy and Messier 1992). Transmission 

of bacteria from gulls to humans is difficult to document; however, Reilly et al. (1981) 

and Monaghan et al. (1985) suggested that gulls were the source of contamination for 

cases of human salmonellosis. Radhouani et al. (2010) documented gulls carrying 

strains of antibiotic-resistant bacteria. Contamination of public water supplies from

gull feces has been stated as the most plausible source for disease transmission (e.g., 

Jones et al. 1978, Hatch 1996). Gull feces has also been implicated in accelerated 
Bird Damage Management in Washington - 33

nutrient loading of aquatic systems (Portnoy 1990), which could have serious 

implications for municipal drinking water sources. 

2.2.4 Terns

In damage situations, terns are generally found damaging aquaculture and feeding on 

T&E salmonid smolt at dams and hatcheries. Increases in tern colonization in western 

WA have impacted rooftops and human health and safety similar to gull populations 

described above. 

Caspian terns (Sterna caspia) are one of the primary avian predators of juvenile 

salmonids in the Columbia River Basin. Caspian terns were first observed nesting in the 

Columbia River estuary in 1984. Approximately 37% of the North American Caspian 

tern population nested in Pacific coastal areas in 2002, with the majority concentrated 

in one colony in the Columbia River Estuary, comprising the largest Caspian tern colony 

in the world [Bird Research Northwest (BRN) online]. USFWS, USACE, WDFW, and 

ODFW developed an EIS studying the impacts of terns throughout California, Oregon, 

Washington, and British Columbia and include increasing nesting habitat throughout

the Pacific Coast and western states in effort to disperse this colony to other areas in

western North America (USFWS 2010 online). 

Additional, smaller Caspian tern colonies exist throughout the Columbia River Basin. 

Current and historic colonies have been located at Crescent Island, Three Mile Canyon 

Island, and Rock Island. Data from Caspian tern colonies in the mid-Columbia River 

show that tern depredation on salmonid smolt, especially steelhead smolt, can be 

substantial13 and that there is a strong correlation between increased predation of 

smolt and the operations of the hydroelectric system (Antolos et al. 2005). 

WS has implemented nonlethal BDM measures to offset damage by Caspian terns and 

does not propose to conduct lethal damage management for Caspian terns. 

2.2.5 Cormorants, Mergansers, and Herons

WS encounters two cormorant species causing damage in WA, double-crested 

cormorant (Phalacrocorax auritus) and pelagic cormorant (P. pelagicus). Doublecrested cormorants damage natural resources, aquaculture, marinas, boat docks, 

shipyards, bridges, electrical transmission structures, and other property. Damage to 

property and structures, such as boat docks and bridges, occurs in the form of fecal and 

nesting materials accumulating on and corroding surfaces and structures. Damage to 

natural resources occurs at dams and hatcheries where cormorants depredate on fish 

stocks and juvenile salmonids. Increasing double-crested cormorant populations 

throughout the Columbia Basin are a growing concern for fisheries managers, as 

cormorants prey on juvenile salmonids. While cormorants are opportunistic feeders 

 

13

 The predation rate by Crescent Island terns on steelhead smolt which migrated through the dams in the 

water (as opposed to being transported around the dams) was as high 12.4% in 2001,which was similar to 

the predation rates on PIT-tagged smolt in the Columbia River estuary (Antolos et al. 2005). 
Bird Damage Management in Washington - 34

and do not specifically target salmonids, where predation does occur, substantial 

numbers of smolt can be consumed (BRN online). Increasing population trends 

through the Columbia Basin are thought to reflect the post-DDT era recovery of the 

Pacific Coast cormorant populations, along with protection under MBTA beginning in 

1972 (BRN online). Pelagic cormorant damage has occurred primarily at marinas, boat 

docks, shipyards, and bridges in marine environments.

Common mergansers (Mergus merganser americanus) are piscivorous waterfowl that 

impact natural resources in WA. Common mergansers are known predators of 

salmonid smolt and under certain conditions may significantly impact migrating 

salmonid populations (Major et al. 2002). Mergansers rank among the most efficient 

predators of juvenile salmon (Wood 1987). Wood (1987) noted that mergansers have 

been documented to feed on salmonids where they are conspicuous relative to other 

species. Mergansers also cause damage at fish hatcheries and aquaculture facilities by 

feeding on, injuring, and stressing fish as a result of their predatory behaviors. 

Great blue herons and green herons (Butorides virescens) cause damage at hatcheries 

and aquaculture facilities by feeding on, injuring, and stressing fish. Great blue herons 

depredate T&E salmonids at dams in the Columbia and Snake Rivers. Great blue herons 

also defecate on boats, docks, and marinas, causing human health and safety concerns 

and property damage complaints. The presence of great blue herons on airfields is a 

significant concern for aviation safety (birdstrikes). 

 2.2.6 Passerines

Native passerines are not generally involved in human-wildlife conflicts; however there 

are a few exceptions where WA WS conducts BDM to alleviate damages or potential 

damages. Ravens are commonly encountered at airports and are involved in 

depredations on new born livestock. Other commonly encountered injurious 

passerines include northern flickers (Colaptes auratus), house finches, and American 

robins. Flickers are commonly associated with damage to homes because of their 

propensity for drilling into siding. American robins and house finches are commonly 

encountered depredating on berry and fruit crops. 

WS assists state agencies with preventing cliff swallows (Petrochelidon pyrrhonota) 

from nesting on bridges prior to construction or maintenance projects. In some cases, 

nests may already be present by the time a request for assistance is received. In these 

cases, WS may be required to remove swallow nests and eggs before construction or 

maintenance project can continue. Failure to take action could lead to critical safety 

projects being uncompleted and delays costing tens of thousands of dollars. 

2.2.7 Shorebirds

Shorebirds in Washington have resident and migrant populations (Larsen et al. 2004). 

The estuaries in the northern Puget Sound provide some of the highest counts of 

shorebirds throughout the state, with estimates exceeding 170,000wintering

shorebirds in WA (Larsen et al. 2004). Shorebirds are rarely encountered in human-
Bird Damage Management in Washington - 35

wildlife conflicts. The primary exception is where shorebirds loaf, feed, and nest on 

airports. 

 2.2.8 Raptors

Nationwide, raptors are the fourth most common group struck by aircraft, making them 

one of the most hazardous birds on airfields. Their tendencies to hover and soar 

frequently place them in the paths of aircraft. Species commonly encountered at 

airports include red-tailed hawks (Buteo jamaicensis), northern harriers (Circus 

cyaneus), and bald eagles (Haliaeetus leucocephalus). Nesting activity on airports 

increases risk to aviation safety, because adults increase hunting and flight activity 

while building nests and rearing young. Raptor nests on communication towers, 

bridges, utility poles, and other structures may impede or prevent maintenance. 

 2.2.9 Introduced and Invasive Species

European starlings, English sparrows, feral pigeons, and other feral birds are not 

protected by USFWS or WDFW and those species, eggs, and nests may be removed 

without permits when causing damage. EO 13112 on invasive species directs federal 

agencies to use their programs and authorities to prevent the spread or to control 

populations of invasive species that cause economic or environmental harm or harm to 

human health. 

These species are found throughout most of WA, in urban and agricultural settings, and 

cause damage to structures, natural resources, and agriculture, and threaten human 

health and safety through fecal contamination and hazardous presence on airfields. 

2.3 T&E Species in Washington

Washington has 60 state and federally listed T&E animal species (Table 2.4). WA WS 

reviewed the list of species and found that for all but the salmonid species, the Proposed 

Action will have “no effect”. Salmonids will be benefitted by the Proposed Action and WS 

determined that this action “may affect, not likely to adversely affect” salmonids.. In 2003, 

NMFS concurred with this finding regarding this scope of activities between river mile 395 

and 517 of the Columbia River. WS will reconsult with NMFS to request their concurrence 

with our “may affect, not likely to adversely affect” determination. 

Table 2.4. State and Federally Listed Species in Washington14.

Species Scientific Name Animal Type State Status Federal Status

Oregon spotted frog Rana pretiosa Amphibian SE FC

Northern leopard frog Rana pipiens Amphibian SE FCo

American white pelican Pelecanus erythrorhynchos Bird SE none

Greater Sage-grouse Centrocercus urophasianus Bird ST FC

Streaked horned lark Eremophila alpestris strigata Bird SE FC

Brown pelican Pelecanus occidentalis Bird SE FCo

Columbian Sharp-tailed Grouse Tympanuchus phasianellus Bird ST FCo

 

14 State Endangered (SE), State Threatened (ST), Federally Threatened (FT), Federally Endangered (FE), 

State Candidate (SC), Federal Candidate (FC), Federal Species of Concern (FCo).
Bird Damage Management in Washington - 36

Species Scientific Name Animal Type State Status Federal Status

Ferruginous hawk Buteo regalis Bird ST FCo

Short-tailed albatross Diomedea albatrus Bird SC FE

Marbled murrelet Brachyramphus marmoratus Bird ST FT

Northern Spotted Owl Strix occidentalis Bird SE FT

Snowy plover Charadrius alexandrinus Bird SE FT

Sandhill crane Grus Canadensis Bird SE none

Upland sandpiper Bartramia longicauda Bird SE none

Mardon skipper Polites mardon Butterfly/Moth SE FC

Taylor's checkerspot Euphydryas editha taylori Butterfly/Moth SE FC

Oregon silverspot butterfly Speyeria zerene hippolyta Butterfly/Moth SE FT

Bocaccio rockfish Sebastes paucispinis Fish SC FE

Chinook salmon (Upper Columbia Sp) Oncorhynchus tshawytscha Fish SC FE

Sockeye salmon (Snake R.) Oncorhynchus nerka Fish SC FE

Bull trout Salvelinus confluentus Fish SC FT

Canary rockfish Sebastes pinniger Fish SC FT

Chinook salmon (Lower Columbia) Oncorhynchus tshawytscha Fish SC FT

Chinook salmon (Puget Sound) Oncorhynchus tshawytscha Fish SC FT

Chinook salmon (Snake R. Fall) Oncorhynchus tshawytscha Fish SC FT

Chinook salmon (Snake R. Sp/Su) Oncorhynchus tshawytscha Fish SC FT

Chum salmon (Hood Canal Su) Oncorhynchus keta Fish SC FT

Chum salmon (Lower Columbia) Oncorhynchus keta Fish SC FT

Coho salmon (Lower Columbia/SW WA) Oncorhynchus kisutch Fish none FT

Eulachon Thaleichthys pacificus Fish SC FT

Green sturgeon Acipenser medirostris Fish none FT

Sockeye salmon (Ozette Lake) Oncorhynchus nerka Fish SC FT

Steelhead (Lower Columbia) Oncorhynchus mykiss Fish SC FT

Steelhead (Middle Columbia) Oncorhynchus mykiss Fish SC FT

Steelhead (Puget Sound) Oncorhynchus mykiss Fish none FT

Steelhead (Snake River) Oncorhynchus mykiss Fish SC FT

Steelhead (Upper Columbia) Oncorhynchus mykiss Fish SC FT

Yelloweye rockfish Sebastes ruberrimus Fish SC FT

Fisher Martes pennant Mammal SE FC

Mazama (Western) pocket gopher Thomomys mazama Mammal ST FC

Tacoma pocket gopher - Mazama Thomomys mazama tacomensis Mammal ST FC

Sea otter Enhydra lutris Mammal SE FCo

Western gray squirrel Sciurus griseus Mammal ST FCo

Black right whale Balaena glacialis Mammal SE FE

Blue whale Baleonoptera musculus Mammal SE FE

Columbian white-tailed deer Odocoileus virginianus leucurus Mammal SE FE

Fin whale Baleonoptera physalus Mammal SE FE

Gray wolf Canis lupus Mammal SE FE

Humpback whale Megaptera novaeangliae Mammal SE FE

Killer whale Orcinus orca Mammal SE FE

Pygmy rabbit Brachylagus idahoensis Mammal SE FE

Sperm whale Physeter macrocephalus Mammal SE FE

Woodland caribou Rangifer tarandus Mammal SE FE

Grizzly bear Ursus arctos Mammal SE FT

Lynx Lynx Canadensis Mammal ST FT

Steller sea lion Eumetopias jubatus Mammal ST FT

Western pond turtle Actinemys marmorata Reptile SE FCo

Leatherback sea turtle Dermochelys coriacea Reptile SE FE

Green sea turtle Chelonia mydas Reptile ST FT

Loggerhead sea turtle Caretta caretta Reptile ST FT

American White Pelican

American white pelicans (Pelecanus erythrorhynchos) are state-endangered piscivorous

birds which are occasionally observed feeding on smolt at hydroelectric facilities. 
Bird Damage Management in Washington - 37

Nesting colonies of American white pelicans were extirpated from WA in the early 

1980’s. A nesting colony of white pelicans was re-established on Badger Island in 1997

in the upper Columbia River (BRN online). In 2010 white pelicans were documented 

nesting in small numbers at two locations on the Columbia River (J. Hoskins, USFWS, 

pers. comm. 2010). Pelicans are routinely seen congregating at outfalls where salmon 

smolt are concentrated. Passive Integrated Transponder (PIT) tag recoveries from the 

Badger Island pelican colony show that less than one PIT-tagged smolt was consumed

per nesting adult. This is a low number compared to other piscivorous birds, such as 

cormorants which consumed 16.2-16.5 PIT-tagged smolt per nesting adult in two 

colonies (BRN online). While their take of salmon smolt is seemingly low, they may 

learn to use the unnaturally susceptible smolt as a greater component of their diets, or 

have a greater impact as their numbers continue to recover. There is concern that this 

species could cause damage to listed fish species in the future, and WS will coordinate 

with WDFW in managing pelican damage. 
Bird Damage Management in Washington - 38

CHAPTER 3 ALTERNATIVES AND METHODS

3.1 Introduction

Alternatives were developed for consideration using the WS Decision Model (Slate et al. 

1992), “Methods of Control” (Appendix J in USDA 1997), and the “Risk Assessment of Wildlife 

Damage Control Methods Used by the USDA Animal Damage Control Program” (Appendix P 

in USDA 1997). Four alternatives were recognized, developed, and analyzed in detail and 

three alternatives (Section 3.3) were considered but not analyzed in detail with rationale. 

3.2 Description of Alternatives Analyzed in Detail

3.2.1 Alternative 1 – Continue the Current WA WS Bird Damage Management 

Program, Nonlethal Preferred Over Lethal Control (No Action/Preferred Alternative).

Alternative 1 is the “No Action” Alternative. The “No Action” Alternative is a procedural 

NEPA requirement (40 CFR 1502.14(d)), and is a viable and reasonable alternative that 

could be selected. This alternative is used as the baseline for comparison with the other 

alternatives. Therefore, information and descriptions provided under this alternative 

and under the analysis of its possible environmental effects may be extended to the 

other alternatives. WA WS provides assistance statewide, including but not limited to 

requests for assistance in natural resource, human health and safety, property, and 

agricultural protection. Management methods would be similar to those currently used 

but could include new technology or methods as they are developed and proven 

effective. While WS cannot anticipate everywhere it may be requested to work, this EA 

analyzes the effects from existing actions while trying to forecast potential needs for 

assistance and analyzes the impacts from those potential actions. Substantial changes 

or additions to the current program would be dependent on the addition of funds and 

support of property owners and other agencies and would be subject to further NEPA 

analysis, as appropriate. 

This alternative consists of the current statewide program of adaptive IWDM TA and 

operational BDM on federal, state, county, city, and private lands under Cooperative 

Agreement, Agreement for Control, or other comparable documents. Preference is 

given to practical and effective nonlethal methods when determining the damage 

management strategy (WS Directive 2.101). However, not all nonlethal methods are 

practical and effective for every damage situation. The current program employs 

methods specific to the risk/level of damage being caused and species involved. 

Operations under this alternative are directed at alleviating damage and not intended to 

control populations of any native species15. 

 

15 In damage situations involving invasive, deleterious exotic, or other non-native species, eradication may be 

a desired goal (locally or state-wide) as directed by EO 13112. Any efforts towards eradication of such 

species would be conducted in cooperation with or at the request of the appropriate state and federal wildlife 

management agencies.
Bird Damage Management in Washington - 39

WS uses the most effective and biologically sound damage management methods (i.e., 

IWDM) to resolve damage caused by birds. In general terms, BDM is comprised of 

practical and effective methods to resolve a particular wildlife problem. The methods 

may include recommending the alteration of habitat and cultural practices, exclusion 

devices, nonlethal harassment, and/or lethal removal (Appendix C). Methods are 

implemented at the field level according to WS Directives 2.101 and 2.105, through the 

WS Decision Model (Slate et al. 1992), and guided by permits, laws and regulations, and 

consultations. WS BDM activities are coordinated, when appropriate, with the USFWS 

and WDFW to avoid adverse effects. 

3.2.2 Alternative 2 – Implement All Nonlethal Methods Before Using Lethal Methods

Alternative 2 would require that all nonlethal methods found in Appendix C be 

implemented before any lethal methods are used by WS, replacing the professional 

judgment applied under the WS Decision Model used in Alternative 1. This alternative 

differs from Alternative 1 in that it would require WA WS to use every nonlethal 

method found in Appendix C and find them to be inadequate/ineffective for each 

damage situation before lethal methods could be implemented. Even if nonlethal

methods are determined to be inappropriate or ineffective, they must be implemented 

before lethal actions are used. The only exception when lethal control may be applied 

first, under this alternative, would be instances where it is necessary to resolve an 

immediate life threatening situation. 

3.2.3 Alternative 3 - Technical Assistance BDM Program Only

WS would not conduct operational BDM activities in WA. If requested, WS would only 

offer TA. Alternative 3 is a modification of Alternative 1 (Nonlethal Preferred), wherein 

no operational BDM would be provided by WS. However, WS could recommend 

operational BDM, but it would be implemented by the affected agency or resource 

owner (e.g., home or business owner). WS would use the WS Decision Model to 

determine recommendations. 

3.2.4 Alternative 4 - No WS BDM Program

This alternative would terminate WS’ role in BDM in WA. Affected agencies and 

resource owners would need to contact other wildlife management agencies/service 

providers or would be left to their own devices to stop/reduce damage caused by birds.

3.3 Alternatives Eliminated from Further Consideration

The following alternatives were evaluated and eliminated from further consideration.

3.3.1 Lethal Methods Only Alternative

The Lethal Methods Only Alternative was analyzed in USDA (1997). This alternative 

would require WS to attempt to reduce or alleviate bird damage or the threat of damage 

through strictly lethal means. This alternative was eliminated for being unrealistic and 

socially and environmentally unacceptable and would not comply with the WS Decision 

Model (Slate et al. 1992).
Bird Damage Management in Washington - 40

3.3.2 Eradication of Native Bird Species Alternative

An eradication alternative would direct all WS Program efforts toward total elimination 

of problematic or nuisance birds in cooperating counties or larger defined areas in WA. 

The eradication of native damaging birds in WA is not a desired goal of state or federal 

wildlife management agencies, including WS. Eradication as a general objective for 

BDM will not be considered by WS in detail because eradication of birds in WA does not 

fall within the mission of WS and would violate state and federal laws. 

3.3.3 Wildlife Damage Must Be an Accepted Loss Alternative

WS is aware that some people feel that BDM should not be allowed until economic 

losses become unacceptable. Although some loss of resources to wildlife can be 

expected and tolerated, WS has a legal obligation to respond to requests for wildlife 

damage management, and it is WS policy to aid each requestor to minimize losses. WS 

uses the Decision Model to determine appropriate strategies. 

In a ruling for the Southern Utah Wilderness Alliance, et al. versus Hugh Thompson, 

Forest Supervisor for the Dixie National Forest, et al., the U.S. District Court of Utah 

upheld the determination that a wildlife damage management program may be 

established based on the threat of damage. In part, the court found that a forest 

supervisor need only show that the threat of damage (from predators) exists in order to 

establish a need for IWDM (Civil No. 92-C-0052A, 20 January 1993). Thus, there is 

precedence for conducting damage management activities when the threat of damage is 

present.

3.4 BDM Strategies Used by WA WS

BDM strategies vary according to the resource being protected, species involved, location 

of the damage, time of year, and other factors. However, WS damage management efforts 

are site-specific and targeted to reduce the specific damage problem. 

During more than 90 years of resolving wildlife damage problems, WS has considered, 

developed, and used numerous methods to reduce damage problems (USDA 1997). WS’ 

efforts include research and development of new methods and implementation of effective 

strategies to reduce and prevent wildlife damage. WS employs different strategies to 

reduce wildlife damage problems, commonly referred to as IWDM. IWDM is the 

implementation and application of safe and practical methods to prevent and reduce 

damage caused by wildlife based on local problem analyses and the informed judgment of 

trained personnel. The WS Program applies IWDM to reduce damage using the WS 

Decision Model (Slate et al. 1992, Section 1.1.2). The philosophy behind IWDM is to 

implement effective management techniques, in a cost-effective manner while minimizing 

the potentially harmful effects to humans, target and non-target species, and the 

environment. IWDM draws from the largest possible array of options to create a 

combination of techniques for each specific situation. IWDM may incorporate cultural 

practices, localized habitat and animal behavior modification, removal of individual 

animals, local population reduction, or any combination of these, depending on the 

characteristics of the specific damage problem.
Bird Damage Management in Washington - 41

3.4.1 Educational Efforts 

Education is an important element of WA WS program activities because wildlife 

damage management is about finding balance and coexistence between the needs of 

people and needs of wildlife. In addition to the routine dissemination of 

recommendations and information to individuals or organizations sustaining damage, 

lectures, instructional courses, and demonstrations are provided to producers, 

homeowners, state and county agents, colleges and universities, and other interested 

groups. WS frequently cooperates with other agencies in educational and public 

information efforts. Additionally, WS personnel and scientists with the WS NWRC

routinely provide technical papers at professional meetings and conferences so that WS 

personnel, other wildlife professionals, and the public are periodically updated on 

recent developments in damage management technology, programs, laws and 

regulations, and agency policies. 

3.4.2 Technical Assistance (TA)

TA is defined as providing advice, recommendations, information, equipment, 

literature, instructions, and materials to assist others in preventing or reducing wildlife 

damage and in understanding BDM principles and techniques. Explanation of the 

biology, behavior, and population ecology of the species responsible for damage is 

occasionally sufficient to satisfy the resource owner’s information needs.

Recipients of WS TA are responsible for the legal and responsible implementation of 

recommended damage management actions. The WS program has no regulatory 

authority or control of the actions taken by others.

3.4.3 Operational Bird Damage Management 

Operational BDM is field activity conducted by WS personnel. It is generally applied 

when the problem cannot reasonably be resolved by TA or when the professional skills 

of WS employees are required for effective problem resolution. Operational BDM 

would only be conducted upon request and after written authorization from the 

landowner, cooperator, or other authorized official(s) is obtained. BDM methods are 

detailed in Appendix C.

3.4.3.1 Preventive Bird Damage Management 

Preventive BDM is the practice of applying damage management strategies before 

damage occurs. Preventive BDM is based on historical problems and the probability 

of the damage recurring or an imminent threat to human health or safety. As 

requested, WS personnel would take action to prevent historical losses from 

recurring or reduce the risk of potential losses from occurring. Some examples 

include the harassment and/or removal of birds or nesting materials from rooftops 

near ventilation intakes before they have caused damage or where they threaten 

human health and safety at airports. 
Bird Damage Management in Washington - 42

3.4.3.2 Corrective Bird Damage Management 

Corrective BDM is the practice of applying damage management to stop or reduce 

existing losses. As requested, WS personnel take appropriate action (e.g., harass, 

remove, etc.) towards birds when damage is occurring. WS does not implement 

BDM for population control of native bird species. 

3.4.4 Research and Development

The NWRC functions as the research arm of WS by providing scientific information for 

the development and improvement of biologically-sound wildlife damage management 

methods. The NWRC, under this EA analysis, could study and develop additional BDM 

methods to reduce bird damage and protect resources. As new methods are developed 

and proven effective they could be incorporated into the current WA BDM program. 

3.5 Minimization Measures and SOPs for BDM Techniques

Minimization measures are any feature of an action that serves to prevent, reduce, or 

compensate for impacts that otherwise might result from that action. The current WS 

program, nationwide, uses many minimization measures, and these are discussed in detail 

in Chapter 5 of USDA (1997). The following measures apply to some or all of the 

alternatives analyzed for the WA WS program, as indicated by an “X” in the column on the 

right side of Table 3-1. 

Alternative 1 – Continue the Current WA WS Bird Damage Management Program (No 

Action/Proposed Action)

Alternative 2 – Implement All Nonlethal Methods Before Using Lethal Methods

Alternative 3 - Technical Assistance BDM Program Only

Alternative 4 - No WS BDM Program
Bird Damage Management in Washington - 43

1 2 3 4

The WS Decision Model is used to identify the most effective 

biologically and ecologically sound BDM strategies and their 

impacts.

X X

Research on selectivity and humaneness of management 

practices would be monitored and adopted as appropriate. X X X

The use/recommendation of capture equipment would conform 

to current laws and regulations administered by USFWS, WDFW 

and WS Policy Directives (APHIS 2010).

X X X

Captured non-target animals would be released unless it is 

determined by the WA WS personnel that the animal would not 

survive.

X X

WS personnel are trained and experienced on all BDM methods 

to select the most appropriate method to reduce damage while 

minimizing take of target animals while excluding non-target 

species. Training details are outlined in the WS Policy Manual 

(APHIS 2010).

X X

WS Specialists would recommend the use of traditional and 

newly developed proven non-lethal methods. X X X

Euthanasia procedures approved by the American Veterinary 

Medical Association (AVMA 2007). These guidelines 

incorporate input from several professional societies and 

international authorities (e.g. American Ornithologists Union, 

American Society of Mammalogists, American Association of 

Avian Pathologists, World Organization for Animal Health, 

International Association of Fish and Wildlife Agencies). 

X X

Operational BDM conducted on public lands would be 

coordinated with the management agency. X X

WA WS’ take is provided to the USFWS and WDFW, and WS 

considered the statewide hunter harvest (WA WS take and other 

take) when estimating WS’ impact on wildlife species.

X X

Management actions would be directed toward localized 

populations and/or individual offending animals, dependent on 

the magnitude of the problem.

X X

Potential impacts on T&E species in WA have been assessed. 

No adverse effects are likely to occur from WS actions (USFWS 

2010, WS 2010).

X X

Table 3-1. Minimization Measures Implemented for Each 

Alternative

Alternatives
Bird Damage Management in Washington - 44

CHAPTER 4 ENVIRONMENTAL CONSEQUENCES

4.1 Environmental Consequences

NEPA requires federal agencies to identify and assess the reasonable alternatives to a 

proposed action that will avoid or minimize adverse effects of these actions upon the 

quality of the human environment (40 CFR 1500.2e). This chapter provides the 

information needed for making informed decisions for selecting the appropriate alternative 

or meeting the need for action and purpose of the proposed action. It analyzes the 

environmental consequences of each alternative analyzed in detail in Chapter 3 in relation 

to the issues identified for detailed analysis. 

The following criteria will aid in determining the environmental consequences in regards 

to each issue (Section 4.2) to determine if the impacts are greater than, less than, or the 

same as the proposed alternative. 

4.1.1 Non-significant Impacts

Soils, geology, minerals, flood plains, visual resources, air quality, or prime and unique 

farmlands within WA are not expected to be significantly affected by any of the 

alternatives analyzed. These resources will not be analyzed further.

4.1.2 Irreversible and Irretrievable Commitments of Resources

No irreversible or irretrievable commitments of resources are expected, other than 

minor uses of fuels for motor vehicles and other similar materials. These will not be 

discussed or analyzed further.

4.1.3 Evaluation of Significance of Cumulative and Unavoidable Impacts

Each issue analyzed in detail is evaluated under each alternative and the direct, indirect, 

and cumulative impacts are analyzed. NEPA regulations describe the elements that 

determine whether or not an impact is “significant.” Significance is dependent upon the 

context and intensity of the action. The following factors were used to evaluate the 

significance of impacts in this EA that relate to context and intensity (adapted from 

USDA 1997) for this proposal.

4.1.3.1 Magnitude of the Impact (size, number, or relative amount of impact) 

Magnitude is defined in USDA (1997) as “. . . a measure of the number of animals 

killed in relation to their abundance” and may be determined either quantitatively 

or qualitatively. Quantitative analysis is used whenever possible as it is more 

rigorous and is based on allowable harvest levels, abundance estimates, and harvest 

data. Qualitative analysis is based on abundance trends and harvest data or trends 

and modeling. Sport harvest levels were obtained from WDFW and USFWS. In the 

discussion that follows, “Other Harvest” refers to the known other take, sport 

harvest, and other information obtained from the WDFW and USFWS. “Total 

Harvest” refers to the sum of the birds removed by WA WS combined with the 

“Other Harvest.”
Bird Damage Management in Washington - 45

4.1.3.2 Duration and Frequency of the Impact

Duration and frequency of BDM in WA is variable. Abiotic and biotic factors 

affecting wildlife behavior affect the duration and frequency of BDM activities 

conducted by WS in WA. BDM in specific areas may be long duration projects, but 

the frequency of individual actions may be variable depending upon any number of 

factors affecting the behavior of the animals that are causing damage and the 

location of the potential damage. BDM would only be conducted by WS when a 

request for assistance is received and a demonstrated need is present. 

4.1.3.3 Geographic Extent 

BDM could occur anywhere in WA where damage management has been requested, 

agreements for such actions are in place, and action is warranted as determined by 

implementing the WS Decision Model (Slate et al 1992). Actions would be limited to 

areas receiving damage from birds, areas with historical bird damage, or where a 

threat of damage exists. 

4.2 Issues Analyzed in Detail

The following environmental issues were identified as relevant to this EA and analyzed in 

detail in Section 4.4.

Effect of methods on non-target and ESA-listed species.

Effect of methods on populations of target species.

Effectiveness of BDM Program in Washington.

Humaneness of methods.

4.3 Issues Not Analyzed in Detail with Rationale

4.3.1 WS’ Impact on Biodiversity 

WA WS does not conduct BDM to eradicate any native wildlife species or control their

populations. WS operates according to federal and state laws and regulations (and 

management plans thereof) enacted to ensure species viability. The effects of the 

current WS program on biodiversity are minor and not significant nationwide, 

statewide, or region-wide (see Section 4.4.1.2). WS operates on an extremely small 

percentage (0.4%) of the land area of WA16 and WS’ take of native wildlife species is a 

small proportion and insignificant to the viability and health of the total population. 

There is no evidence to suggest that WA WS BDM, as proposed, would have any adverse 

direct, indirect, or cumulative effects on biodiversity. 

4.3.2 Appropriateness of Preparing an EA (Instead of an EIS) 

Some individuals might question whether preparing an EA for the state of WA would 

meet the NEPA requirements for site specificity. If a determination is made through 

 

16 Usually in areas with human developments (e.g., agriculture, airports, landfills and waste transfer stations, 

utilities, industrial areas, cities, etc.)
Bird Damage Management in Washington - 46

this EA that the proposed action would have a significant environmental impact, then 

an EIS would be prepared. In terms of considering cumulative impacts, one EA 

analyzing impacts for the entire state may provide a better analysis than multiple EA’s 

covering smaller zones. In addition, WA WS only conducts BDM in a very small area of 

the State (0.4%) where damage is occurring or likely to occur.

4.3.3 Cost Effectiveness of Bird Damage Management

CEQ does not require a formal, monetized cost-benefit analysis to comply with NEPA 

(40 CFR 1502.23) and consideration of this issue is not essential to making a reasoned 

choice among the alternatives being considered. USDA (1997, Appendix L) states:

“Cost effectiveness is not, nor should it be, the primary goal of the APHIS WS 

program. Additional constraints, such as the environmental protection, land 

management goals, and others, are considered whenever a request for assistance is 

received. These constraints may increase the cost of the program while not 

necessarily increasing its effectiveness, yet they are a vital part of the APHIS WS 

Program.”

An analysis of cost-effectiveness in many BDM situations is exceedingly difficult or 

impossible to perform because the value of benefits is not readily determined. For 

example, the potential benefit of reducing bird risks at airports or eliminating pigeons 

from nesting in industrial buildings could reduce birdstrikes or incidences of illness 

among unknown numbers of building users. Since some birdstrikes or bird-borne 

diseases are potentially fatal, or severely debilitating, the value of the benefit may be 

high. However, no studies with and without BDM have been conducted, and, therefore,

the number of cases prevented by effective BDM is not possible to estimate. 

4.3.4 Bird Damage Management Should Be Conducted by Private Nuisance Wildlife 

Control Agents 

Private nuisance wildlife control agents could be contacted to reduce bird damage for 

property owners or property owners may attempt to reduce their own damage 

problems. Some property owners would prefer to use a private nuisance wildlife 

control agent because the nuisance wildlife agent is located in closer proximity, they are 

not required to comply with NEPA, or because they prefer to use a private business 

rather than a government agency. However, some property owners would prefer to 

contract with a government agency. In particular, large industrial businesses, airport 

managers, and cities and towns may prefer to use WS because of security and safety 

issues, legal requirements to be accountable to the public through NEPA compliance,

and reduced administrative burden.

4.3.5 Effects from the Use of Lead Ammunition in Firearms

Questions have arisen about the deposition of lead into the environment from 

ammunition used in BDM. To address lead exposure, WA WS complies with USFWS 

requirements for the use of non-toxic shot pursuant to USFWS depredation permits and 

depredation orders. Additionally, WA WS preferentially uses non-toxic shot for the 
Bird Damage Management in Washington - 47

control of non-migratory or non-native birds unless necessary to alleviate safety 

concerns (e.g., ricochets).

Where appropriate, some birds may be taken with rifles or other firearms using lead 

bullets. Birds taken with lead bullets are retrieved and disposed to prevent access by 

scavengers. A minimal amount of lead from bullets may enter the environment if a 

bullet passes through a bird, a miss occurs, or the carcass cannot be retrieved.

In an ecological risk assessment of lead shot exposure to non-waterfowl birds, the 

ingestion of lead shot, rather than just contact with lead, was identified as the concern 

(Kendall et al. 1996). Birds most commonly ingest lead shot in areas where it has 

accumulated over time from extensive or repetitive shooting activities. WS’ use of lead 

is minimal and randomly distributed throughout the state, and is not concentrated in 

small, specific areas like shooting ranges or wetlands. WS abides by state and federal 

regulations regarding where and when lead shot or bullets may be used. Based on 

current information, lead deposited in the environment, in such low levels, does not 

pose a risk of exposure or water contamination. 

4.3.6 Perception of Aesthetics 

Aesthetics is the philosophy dealing with the nature of beauty or the appreciation of 

beauty. Therefore, aesthetics is subjective in nature, dependent on what an observer 

regards as beautiful or distasteful. The mere knowledge that wildlife exists is a positive 

benefit to many people (Fulton et al. 1996). Human dimensions of wildlife damage 

management include identifying how people are affected by problems or conflicts 

between them and wildlife, attempting to understand people’s reactions, and 

incorporating this information into policy and management decision processes and 

programs (Decker and Enck 1996, Decker and Chase 1997). Aesthetically speaking, a 

passerby may view a large flock of feeding birds with great delight, whereas another 

person (e.g., property owner experiencing wildlife damage) may view the same birds 

with displeasure.

Some bird species have increased in abundance to where their current populations are 

much higher than they were historically, and are often the result of human-induced 

environmental changes. Conover (2002) describes species whose current population 

exceeds historical levels due to human-caused environmental changes as being 

“anthropogenic abundant.” Many native birds we think of as common due to their 

current abundance are anthropogenic abundant and they often cause environmental 

changes, but when these changes are not to society’s liking, it is considered

environmental degradation or destruction (Conover 2002). For instance, many 

anthropogenic abundant species have contributed to the decline of some native species, 

including endangered species, through excessive predation, competition, or disease 

transmission (Goodrich and Buskirk 1995). The exponential increase of urban geese in 

Seattle, which occurred in the 1990s, provides a recent example of an anthropogenically 

abundant species. 

“Wildlife acceptance capacity” is the limit of human tolerance for wildlife or the 

maximum number of a given species that can coexist compatibly with local human 
Bird Damage Management in Washington - 48

populations (Decker and Purdy 1988). Wildlife acceptance capacity is also known as 

the “cultural carrying capacity.” These terms are important because they define the 

sensitivity of a local community to a specific wildlife species. For any given damage 

situation, there will be varying thresholds by those directly and indirectly affected. This 

threshold of damage or potential damage is a primary limiting factor in determining the 

wildlife acceptance capacity. The wildlife acceptance capacity reflects the acceptance of 

one key constituency for a species at a given point in time, thus, different key 

constituency groups can simultaneously have different wildlife acceptance capacities 

that reflect their particular set of pertinent limiting factors relative to a particular 

wildlife population (Decker and Purdy 1988).

WS recognizes the aesthetic importance of wildlife and associated viewing and 

recreational opportunities. Under the current program there may be a local, sitespecific effect on people’s opportunities to view some individual birds or flocks. 

However, bird populations as a whole have not been negatively affected by WA WS, and 

there has been no measurable decline in public viewing opportunities. This trend 

would be expected to continue. 

4.4 Alternatives Analyzed in Detail

4.4.1 Alternative 1: Continue the Current WS BDM Program, with Nonlethal 

Preferred Over Lethal Control (No Action/Proposed Alternative)

Alternative 1 is the “No Action” Alternative, which is a procedural NEPA requirement 

[40 CFR 1502.14(d)]. This alternative would continue the current program, an adaptive 

IWDM approach, which includes the use of a combination of nonlethal and lethal 

methods based on case-by-case situations. Nonlethal methods are preferred and used 

first when they are deemed practical and effective (WS Directive 2.101). 

4.4.1.1 Effect of Damage Management Methods on Non-target and ESA-listed Species

Non-lethal Methods

Overall, impacts to non-target species from the use of nonlethal methods would be 

similar to the use of nonlethal methods under any of the alternatives. Non-target

species would generally be unharmed from the use of nonlethal methods under any 

of the alternatives since no lethal take would occur. Nonlethal methods would be 

available under this alternative and WS’ involvement in the use of or 

recommendation of nonlethal methods would ensure non-target species impacts are 

considered under WS’ Decision Model. 

Only repellents registered with the EPA pursuant to FIFRA and registered for use in 

WA would be recommended and used by WS under this alternative, [e.g., Methyl 

Anthranilate]. The use and recommendation of repellents by WA WS would not 

have negative impacts on non-target species when used according to label 

requirements. Most repellents are derived from natural ingredients that pose a very 

low risk to non-target species when exposed to or when ingested. 
Bird Damage Management in Washington - 49

Lethal Methods

WS could employ and/or recommend lethal methods under the proposed 

alternative to alleviate damage. Lethal methods available for use to reduce damage 

caused by birds under this alternative would include shooting, traps, Sodium Lauryl 

Sulfate (SLS) and the avicides DRC-1339 and Avitrol. In addition, birds could also be 

euthanized once live-captured by AVMA approved methods; lethal take of livecaptured birds would occur pursuant to WS Directive 2.505. Available methods and 

the application of those methods to resolve bird damage is further discussed in 

Appendix C. 

Shooting would be used for lethal reinforcement and as the last step of this 

integrated BDM program. Lethal reinforcement is heavily prefaced with one or 

more forms of habitat management, exclusion, and/or harassment. In nearly every 

case, most bird species habituate to nonlethal methods and continue to damage or 

threaten damage. When this occurs, at least one individual is shot to serve as a 

warning to the rest of the flock; in some instances, multiple individuals are shot 

before the flock finally departs the area. Throughout the course of a day, the same 

flock, or members of that flock, may return to the site. Harassment is repeated and 

if the birds fail to depart, lethal reinforcement may be repeated. After several days 

or weeks of this, these flocks or persistent individuals generally vacate the site. 

Often, the bird’ behavior will change and they will flush from the sight when WS 

vehicles approach. When this occurs, WS assumes that these birds have habituated 

to management, but the birds may still be present on the site whenever WS is not. It 

is also obvious when new birds (e.g., migrants) unfamiliar with the above practices 

are present because these birds do not depart when WS approaches. These 

individuals/flocks are then conditioned just as described above. 

At multiple damage locations, where WS conducts ongoing BDM programs, it is 

possible to have individuals or thousands of birds a day trying to use the site. It is 

imperative to continue to condition the birds to keep them from establishing at the 

site and for the reduction of damage. If some birds, particularly gulls, are allowed to 

persist at the site, they serve as decoys to other birds to use the site. This is why WS 

makes significant effort to deter and harass all birds from damage sites. Continually 

harassing habituated birds (without using lethal reinforcement) frequently serves 

to decoy in additional birds, prolong the damage experienced, and potentially 

results in the need for substantially more lethal reinforcement at a later time.

Birds that have habituated to WS personnel and vehicles are nearly impossible to 

apply lethal reinforcement upon. At many of the sites where WS has ongoing BDM

programs, it is common for new birds, particularly gulls, to show up in groups of one 

to hundreds of birds. 

The use of firearms is selective for target species since animals are identified prior 

to shooting; therefore, no adverse impacts are anticipated from WS’ use of this

method. When using pesticides, WS follows all pesticide label requirements to 

minimize hazards to non-target species. When required, bait sites are pre-baited 

and monitored for non-target species use, as outlined in the pre-treatment 
Bird Damage Management in Washington - 50

observations section of the label. By acclimating target species to a feeding 

schedule, baiting can occur at specific times to ensure bait is quickly consumed by 

target species, and is unavailable to non-target species. If non-target species are 

observed feeding on the pre-bait, the plots are abandoned and no baiting would 

occur at those locations. The selection of bait type can also limit the likelihood that 

non-target species will consume treated bait, since some bait types are not 

preferred by non-target species. 

Once sites are baited, they are monitored to further observe for non-target species 

feeding activity. If non-target species are observed feeding on bait, they are 

harassed from the area or the bait is removed and those sites are abandoned. When 

baiting is complete, any uneaten baits are picked-up and safely disposed on the 

same day of the treatment; no bait is left unobserved. 

The methods used under Alternative 1 are selective for target species. There has 

been no measurable adverse effect observed on non-target species and no adverse 

effect on ESA-listed species. Operational damage management conducted by WA

WS may include harassment, exclusion, shooting, capture and euthanasia, pesticides, 

and other methods discussed in Appendix C which are determined to be practical, 

legal, and effective. 

WS initiated consultation with USFWS during the preparation of this EA to 

determine whether the proposed action will affect ESA-listed species. 

4.4.1.2 Effect of Take on Populations of Target Species

BDM incorporates a variety of lethal and nonlethal methods (Appendix C), to reduce 

damage and/or risk of damage to resources. When responding to damage by native 

bird species, WS may use lethal reinforcement to enhance behavioral response to 

nonlethal methods. Lethal management is typically required when bird population 

densities are relatively high and nonlethal methods are ineffective or the birds have 

habituated to them. WA WS strives to limit take of native species of birds. For FY06 

through FY10, lethal actions comprised only 1.04% of all BDM activities involving 

bird species (excluding feral, Depredation Order, and invasive species). In addition, 

through the annual federal depredation permit renewal process administered by the 

USFWS, WS coordinates the take of MBTA protected species with the USFWS 

Migratory Bird Office to ensure WS’ actions will not adversely impact populations. 

When responding to damage by non-native, invasive, or introduced species (e.g., 

European starlings, feral pigeons, or others), WS may use lethal methods to 

specifically reduce localized populations.

In the interest of preserving public safety, WS may conduct BDM involving species 

not anticipated in this document. One example would be airports which receive 

depredation permits from USFWS, monitored and renewed annually, to protect 

aviation and public safety. These permits allow for take of any migratory bird 

species (except T&E listed species and bald and golden eagles) that pose an 

immediate threat to aviation or human health and safety. WS may be requested to 

assist airports and conduct management actions under those permits at any time.
Bird Damage Management in Washington - 51

Wildlife populations are difficult to count, so WA WS uses the best available 

population data (be it numbers or trends) from multiple sources to attempt to 

accurately assess populations. 

In the following analysis, the magnitude of WS’ effect is measured for those species 

that were lethally removed during BDM actions17. The analysis for magnitude of 

effect generally follows the process described in Chapter 4 of USDA (1997), which 

defines magnitude as “... a measure of the number of animals killed in relation to their 

abundance.” Magnitude can be determined either quantitatively or qualitatively. 

WA WS take is presented as 5-year averages for activities from FY06 through FY10

(Appendix A). The analysis considers a level of take that may be necessary to 

sufficiently reduce damages and meet future requests for assistance. However, the 

numbers presented do not necessarily represent planned take. All take of migratory 

bird species is regulated and permitted in advance by the USFWS and any future 

requests for take would be reviewed and analyzed by the USFWS before the 

necessary permits are issued18. 

WS responds to requests for assistance and may be asked to provide assistance at 

any time. The level of take analyzed in this EA is higher than what is currently 

occurring to account for possible future requests which could include additional 

assistance at airports, agricultural producers, and hydroelectric facilities across WA. 

Under NEPA CEQ regulations, federal agencies are directed to take immediate action 

to secure human lives. The protection of human safety at airports is a priority for 

WS, so analyzing a level of potential take that facilitates that mission, while not 

impacting those wildlife populations, is essential although exact numbers cannot be 

predicted.

4.4.1.2.1 Waterfowl

Migratory waterfowl are managed and protected by the USFWS and WDFW. As 

part of their regulatory authority, the USFWS may issue depredation permits to 

WS and others to take waterfowl species. Nearly all WS take of waterfowl occurs 

at airports under each airport’s USFWS issued depredation permit. WS expects 

this need to continue and will provide assistance, as requested. The majority of 

waterfowl species are also legally hunted in WA with seasons and bag limits set by 

both agencies. 

There are several standards of comparison available to determine the impacts of 

WS activities on waterfowl populations19. Population estimates provide an index 

 

17 Under the current USFWS permit, “up to 10 birds per species [not listed on the existing permit], excluding 

bald and golden eagles and T&E species, may be taken [annually], however, there is no limit on the number 

taken at airports in emergency situations”.

18 Species included in depredation orders or non-native, exotic species do not require permits. 

19 The primary survey to determine status of wintering waterfowl is the January Midwinter Waterfowl 

Survey, which is a combined effort of WDFW, ODFW, Yakama Nation, USFWS, and Canadian Wildlife Service. 

Other surveyed regions include the north Puget Sound and other key wintering areas from October through 

March. 
Bird Damage Management in Washington - 52

for comparison from year to year, based on the application of the same 

methodologies, and are not a census of waterfowl populations. Harvest estimates 

are established using voluntary hunter-completed surveys and are provided for 

comparison purposes20. As part of the following analysis, WS consulted with 

WDFW regarding take of waterfowl. WDFW does not expect any adverse effects 

from the removal of up to 300 mallards and 50 of each other waterfowl species 

per year (excluding harlequin (Histrionicus histrionicus), brant (Branta bernicla), and 

dusky Canada geese (B. canadensis occidentalis)) (Don Kraege, WDFW, pers.

comm. 2010). 

American Wigeon Population Impacts

The estimated average American wigeon (Anas americana) wintering population 

in WA from 2006 through 2009 was 139,519 (WDFW 2009). USFWS breeding 

surveys of waterfowl breeding grounds in Canada and Alaska in 2009 show that 

wigeon abundance was similar to 2008 and the long term average (2.5±0.1 

million). Breeding Bird Survey (BBS) population trend data from 1966 to 2009

shows wigeon populations are relatively stable in WA since 1968 (Sauer et al. 

2011). 

From FY06 through FY10, WS dispersed an average of 659 and lethally removed 

an average of 18 wigeon per year on projects relevant to this EA. WS could take 

50 wigeon per year, equal to about 0.004% of the estimated population, and would 

not significantly impact the distribution, abundance, or population trend of the 

species.

American Green-winged Teal Population Impacts

The estimated average American green-winged teal (A. creeca) wintering

population in WA from 2006 through 2009 was 22,780 (WDFW 2009). USFWS 

breeding surveys of waterfowl breeding ground in Canada and Alaska in 2009 

show that the population was similar to 2008 levels (3.4 ±0.2 million) and well 

above the long term average (USFWS 2009). BBS population trend data from 

1966 to 2009 shows the green-winged teal population has been stable in WA since 

about 1978 (Sauer et al. 2011). 

From FY06 through FY10, WS dispersed an average of 343 and lethally removed 

an average of 18 green-winged teal per year on projects relevant to this EA. Based 

on the yearly average, WS took 0.08% of the estimated green-winged teal 

wintering population in WA. Though not anticipated, WS could take up to 50

green-winged teal per year, equaling about 0.2% of the estimated population, and 

would not significantly impact the distribution, abundance, or population trend of 

the species.

 

20 Survey methodology for estimating populations and harvest can be found in USFWS 2009 and Raftovich et 

al. 2009, accordingly. 
Bird Damage Management in Washington - 53

Bufflehead Population Impacts

The estimated average bufflehead (Bucephala albeola) wintering population in WA 

from 2006 through 2009 was 21,527 (WDFW 2009). The BBS population trend 

data from 1966 to 2007 shows the bufflehead population is stable in WA (Sauer et 

al. 2011). 

From FY06 through FY10, WS dispersed an average of 7,785 and lethally removed 

an average of 11 bufflehead per year on projects relevant to this EA. Based on the 

yearly average, WS took less than 0.05% of the estimated bufflehead wintering 

population in WA. WS could take up to 50 bufflehead per year, less than 0.2% of

the estimated wintering population (not all bufflehead are taken during the 

winter), and would not significantly impact the distribution, abundance, or 

population trend of the species.

Gadwall Population Impacts

The estimated average Gadwall (A. strepera) wintering population in WA from 

2006 through 2009 was 5,568 (WDFW 2009). USFWS breeding surveys of 

waterfowl breeding grounds in Canada and Alaska in 2009 show that the 

population was similar to 2008 levels (3.1 ±0.2 million) and 73% above the long 

term average (USFWS 2009). BBS population trend data from 1966 to 2009

shows the gadwall population has steadily increased in WA since about 1978 

(Sauer et al. 2011). 

From FY06 through FY10, WS dispersed an average of 474 and lethally removed 

an average of 17 gadwall per year on projects relevant to this EA. WS could take 

up to 50 gadwall per year, less than1% of the estimated population (not all 

gadwall are taken during the winter), and would not significantly impact the 

distribution, abundance, or population trend of the species.

Mallard Population Impacts

The estimated average mallard (A. platyrhynchos) population in WA from 2006 

through 2009 was 359,501 (WDFW 2009). USFWS breeding surveys of waterfowl

breeding grounds in Canada and Alaska in 2009 show that the population of

mallards in 2009 (8.5±0.2 million) was 13% higher than the long term average. 

The BBS population trend data from 1966 to 2009 shows the mallard population 

is stable in WA (Sauer et al. 2011).

From FY06 through FY10, WS destroyed an average of 6 mallard eggs, dispersed 

an average of 1,663 birds, and lethally removed an average of 122 mallards per 

year on projects relevant to this EA. WS could take up to 300 mallards per year, 

equaling 0.08% of the estimated WA population, and would not significantly 

impact the distribution, abundance, or population trend of the species.
Bird Damage Management in Washington - 54

Northern Shoveler Population Impacts

The estimated average northern shoveler (A. clypeata) wintering population in 

WA from 2006 through 2009 was 4,444 (WDFW 2009). USFWS breeding surveys 

of waterfowl breeding grounds in Canada and Alaska in 2009 show that the 

population was 25% above the 2008 levels (4.4 ±0.2 million) and 92% above the 

long term average (USFWS 2009). The BBS population trend data from 1966 to 

2009 shows the shoveler population is relatively stable in WA (Sauer et al. 2011). 

From FY06 through FY10, WS dispersed an average of 66 and lethally removed an 

average of 10 shovelers per year on projects relevant to this EA. WS could take up 

to 50 shovelers per year, less than1.3% of the estimated wintering population (not 

all shovelers are taken during the winter), and would not significantly impact the 

distribution, abundance, or population trend of the species.

Ring-necked Duck Population Impacts

The estimated average ring-necked duck (Athaya collaris) wintering population in 

WA from 2006 through 2009 was 14,364 (WDFW 2009). USFWS breeding 

surveys of waterfowl breeding grounds do not include ring-neck ducks in the 

Pacific Flyway. The BBS population trend data from 1966 to 2009 shows the ringnecked duck population is increasing in WA (Sauer et al. 2011). 

From FY06 through FY10, WS dispersed an average of 414 and lethally removed 

an average of 11 ring-necked ducks per year on projects relevant to this EA. WS 

could take up to 50 ring-necked ducks per year, about 0.3% of the estimated 

wintering population (not all ring-necked ducks are taken during the winter), and 

would not significantly impact the distribution, abundance, or population trend of 

the species.

Canada Goose Population Impacts

The estimated average wintering population of Canada geese in WA from 2006

through 2009 was 44,344 (WDFW 2009). The BBS population trend data from 

1966 to 2009 shows that breeding populations of Canada geese have increased 

since 1980 and have increased steadily over the past 30 years in WA (Sauer et al. 

2011). 

From FY06 through FY10, WS dispersed an average of 688, and lethally removed 

an average of 23 Canada geese per year on projects relevant to this EA21. WS could 

take up to 50 Canada geese per year, equaling about 0.11% of the estimated 

wintering population (not all Canada geese are taken during the winter), and 

would not significantly impact the abundance, distribution, or population trend of 

the species. 

 

21 Analysis of resident Canada goose management was conducted under the USFWS Resident Canada Goose EIS. 
Bird Damage Management in Washington - 55

Greater White Fronted Goose Population Impacts

The Pacific population of greater white-fronted geese (Anser albifrons) nests on 

the Yukon-Kuskokwim Delta and winter in the Central Valley of California. USFWS 

surveys of the breeding grounds estimated the 2009 fall population at 536,700 

(USFWS 2009). 

WS first noted greater white-fronted geese showing up at airports in western WA 

in 2008, and it may be necessary to deter this species from airports in the future. 

From FY06 through FY10, WS dispersed an average of 195 and lethally removed 

an average of one greater white-fronted goose per year on projects relevant to this 

EA. For analysis purposes, WS could take up to 50 greater white-fronted geese per 

year, equaling 0.009% of the estimated Pacific population, and would not 

significantly impact the distribution, abundance, or population trend of the 

species.

Tundra Swan Population Impacts

Tundra swans (Cygnus columbianus) are susceptible to lead poisoning, and large 

die offs have occurred, but the WA population appears stable (Seattle Audubon 

2005). According to WDFW (2009), the most recent estimates of the wintering 

western WA tundra swan population in WA was 3,380.

From FY06 through FY10, WS dispersed an average of 79 and lethally removed an 

average of one tundra swan(s) per year on projects relevant to this EA. In 2008, 

WS first documented the presence of swans in large numbers at a military airfield 

in western WA, posing a highly significant threat to aviation safety. WS could take 

up to six tundra swans per year, equaling 0.2% of the estimated western WA 

wintering population, and would not significantly impact the abundance, 

distribution, or population trend of the species. 

Trumpeter Swan Population Impacts

WA WS took no trumpeter swans (C. buccinators) during the analysis period. In 

2008, WS documented the presence of swans in large numbers at a military 

airfield in western WA, posing a highly significant threat to aviation safety. The 

species is susceptible to lead poisoning, and large die offs have occurred, but the 

WA population appears stable (Seattle Audubon 2005). According to WDFW 

(2009), the most recent estimates of the wintering western WA trumpeter swan 

population in WA was 9,852. WS could take up to six trumpeter swans per year, 

equaling 0.06% of the estimated western WA wintering population, and would not 

significantly impact the abundance, distribution, or population trend of the 

species. 
Bird Damage Management in Washington - 56

4.4.1.2.2 Gulls

Gulls comprise a migratory group that is managed and protected by the USFWS 

and WDFW. As part of their regulatory authority, the USFWS issues depredation 

permits to WS and others to take gulls to protect human health and safety, 

property, natural resources, and agriculture. WS expects requests to reduce gull 

damages to continue and will provide assistance, as requested. The numbers 

presented in the analysis below do not necessarily represent planned take. All 

take of migratory bird species is regulated and permitted in advance by the 

USFWS and any future requests for take would be reviewed and analyzed by the 

USFWS before any permits are issued.

Glaucous-winged Gull/Western Gull Population Impacts

Glaucous-winged gulls (Larus glaucenscens) are common residents on the Pacific 

Northwest coast and hybridize extensively with western gulls (L. occidentalis)

(Hayward and Verbeek 2008). For that reason, these species along with their 

hybrids are considered together for this review. The North American population 

of glaucous-winged gulls was estimated at 380,000 breeding birds with stable

population trends and western gulls were estimated at more than 77,000 with 

stable to increasing population trends (Kushlan et al 2002). A survey completed

in the early 1980s, estimated that there were 37,000 glaucous-winged 

gulls/western gulls in WA. The most recent information on glaucous-winged 

gulls/western gulls includes estimates for colonies at Destruction Island and

Protection Island in 2006 (204 and 4,483, respectively), Puget Sound except 

Destruction Island in 2007 (6,029) and the Columbia River Estuary in 2009 

(8,073), for a total WA/Columbia River nesting population of 18,789 birds (9394 

pairs). These surveys attempted include gull colonies, larger than 30 nests,

nesting on buildings and structures along the shoreline, but did not capture data 

for “inland” colonies (USFWS unpubl. data) or small groups of nesting birds typical 

of inland and near-shore urban areas (USDA unpubl. data). WS has counted more 

than 10,000 glaucous-winged gulls at one landfill on multiple winter days. 

The majority of conflicts with glaucous-winged gulls/western gulls occur in urban 

and suburban environments in the areas surrounding Puget Sound and along the 

Pacific coast, sometimes more than 15 miles inland from the nearest marine 

water. Inland landfills, trash transfer stations, and airports, marinas, and rooftops 

account for most conflicts. Most of the gulls nesting, feeding, or residing in these 

locations have historically escaped population inventories. The expansion of gull 

populations into urban areas is not a new phenomenon and has been documented 

since 1946 in Commencement Bay (Eddy 1982). Glaucous-winged gulls have been 

observed nesting at numerous ferry terminals throughout the Puget Sound and on 

rooftops in Bremerton and Seattle (Eddy 1982, USDA unpubl. data). WS biologists 

have also observed numerous small nesting populations (fewer than 30 pair) of 
Bird Damage Management in Washington - 57

glaucous-winged gulls in other cities and locations (primarily rooftops) around 

Puget Sound that have not been inventoried in official gull surveys (MIS 2011). 

The majority of WS’s lethal take of glaucous-winged gulls/western gulls occurs at 

landfills and trash transfer stations during the fall through spring migration 

period (October through February) and most likely involves wintering migrants, 

not the local breeding population. WS estimates that between 1⁄4 and 1⁄3 of the 

gulls removed during this time are sub-adults that are not routinely counted in 

any of the breeding colony surveys. This period is when WS conducted the 

majority of its nonlethal management efforts as well. Based on the timing of these 

efforts and the response of individuals and flocks to lethal reinforcement efforts, 

the vast majority of these birds are believed to be migrants. On average, 574 

glaucous-winged gulls/western gulls were killed each year from May through 

August, FY06 through FY10 (Figure 4.1, MIS 2011).

Lethal reinforcement is simply the last step of an integrated control program. It is 

heavily prefaced with one or more forms of habitat management, exclusion, 

and/or harassment. In nearly every case, gulls quickly habituate to these 

nonlethal methods and continue to damage or threaten damage. When this 

occurs, at least one individual is shot to serve as a warning to the rest of the flock. 

In some instances, multiple individuals are shot before the flock finally decides to 

depart the area. Throughout the course of a day, the same flock, or members of 

that flock, may return. Harassment is repeated and if the birds fail to depart, lethal 

reinforcement is repeated. After a few days or weeks of this, these flocks or 

persistent individuals learn to recognize WS’ presence at the damage site (vehicles 

as well as personnel). Often, birds will flush from the sight of WS vehicles 

approaching from several hundred yards away. When this occurs, WS knows that 

these birds have habituated to management methods and know that they may be 

present on the site whenever WS is not. It is obvious when new birds unfamiliar 

with the above practices are present because these new birds do not depart when 

WS approaches. These individuals/flocks must be conditioned just as described 

above. 

At multiple damage locations where WS conducts ongoing gull damage 

management programs, it is possible to have individuals or thousands of gulls a 

day trying to use the site. It is imperative that gulls never think they can 

sometimes get away with being present on the damage site. If some are allowed to 

persist, they serve as decoys to other gulls flying by. This is why WS makes 

significant effort to deter and harass all gulls from damage sites. 
Bird Damage Management in Washington - 58

Gulls may appear 

as individuals or 

in flocks of 

hundreds. If they 

fail to depart 

when WS 

personnel 

approach, they are 

addressed as new 

birds and 

harassed heavily. 

Lethal 

reinforcement 

may soon follow if 

they fail to depart. 

If all or most begin 

to depart, they may be considered habituated birds and harassment may be 

employed or an individual may be shot to reinforce that this is not an 

acceptable/safe area for them to loaf/feed at. Continually harassing habituated 

birds (without using lethal reinforcement) frequently serves to decoy in additional 

birds, prolong the damage experienced, and potentially results in the need for 

substantially more lethal reinforcement later on. 

Birds that have habituated to WS personnel and vehicles are nearly impossible to 

apply lethal reinforcement upon. New birds, that do not respond may be shot. At 

many of the sites where WS has ongoing gull damage management programs, it is 

common for new gulls to show up in groups of one to hundreds of birds. WS has 

counted more than 10,000 GWGUs at one landfill on multiple winter days. 

Because of their response to WS vehicles and personnel, it is easy to distinguish 

how frequently migrating birds arrive at the damage sites and to confidently 

declare that most of the gulls WS takes during the months of October through 

March are migrants. In addition, WS estimates that between one-quarter and onethird of the gulls removed during this time are sub-adults that are not routinely 

counted in any of the breeding colony surveys. 

Glaucous-winged gull egg control projects occur in the late spring through 

summer on rooftops in urban and suburban areas, usually with fewer than 12 

nests per building, and adjacent to the Puget Sound (MIS 2011). While conducting 

their regular projects, WS biologists and specialists can identify multiple other 

rooftops with 1-30 nests per building and WS is not under agreement to work on 

any of those buildings. Therefore, WS is confident that the nests and eggs WS 

removes, and uncountable others, are not any of those counted during USFWS 

surveys and that aerial counts of rooftop nests result in the omission of significant 

numbers of nests.
Bird Damage Management in Washington - 59

More than 99% of the BDM actions taken by WS in the reduction of conflicts with 

glaucous-winged/western gulls were nonlethal. From FY06 through FY10, WS 

harassed an average of 387,167 glaucous-winged/western gulls, lethally removed 

an average of 3,749 birds, and removed an average of 3,408 eggs each year. All WS 

egg removal occurred on “non-natural” anthropogenic features such as rooftops

and other features in urban and suburban areas. This activity serves an important 

role in discouraging the increasing shift in nesting into urbanized and industrial 

areas. Lethal take by entities other than WS did not exceed more than 200 birds 

per year, and would not significantly increase the cumulative effects of WS BDM

on the glaucous-winged/western gull populations. The BBS shows the glaucouswinged/western gull population continues to be healthy in WA, concurrent with 

WS’ BDM activities (Figure 4.2).

Based on the historic annual average take, anticipated projects, and the positive 

trend in the Washington and Western BBS Region glaucous-winged/western gull

population (Sauer et al. 2011), WS could be requested to remove up to 4,100 birds 

and 4,500 eggs per year to protect resources. As required through the annual 

federal depredation permit renewal process, WS will coordinate with the USFWS 

Migratory Bird Office to ensure WS’ actions will not adversely impact glaucouswinged/western gull populations.

Figure 4.2 BBS Trend for Glaucous-winged Gulls in Washington (left) and the Western BBS Region 

(right) for 1968-2009 (Sauer et al. 2011).

Herring Gull Population Impacts

Herring gulls (L. argentatus) are common in WA and may hybridize with glaucouswinged gulls (Pierotti and Good 1994). WS dispersed an average of 10,581 and 

lethally removed an average of 68 herring gulls per year. The overall population 

trend for herring gulls in the western BBS region remains stable (Sauer et al. 

2011). Based on the yearly average, anticipated projects, and stable population

trend, WS could possibly be requested to remove up to 150 herring gulls to protect 
Bird Damage Management in Washington - 60

resources, which would not impact the distribution, abundance, or population 

trend of the species. 

California Gull Population Impacts

Winkler (1996) in the Birds of North America (BNA) estimated the total North 

American population of California gulls at 500,000 - 1,000,000 birds. The 

breeding population is estimated at 

414,000 breeding birds with stable 

trends (Kushlan et al. 2002, Sauer et al. 

2011) (Figure 4.3). In Washington and 

along the Columbia River corridor, the 

number of breeding California gulls was 

9,052 birds (4,526 pairs) at nine 

colonies in 1977 (Conover 1979). This 

number increased to 37,679 birds 

(18,839 pairs) in 2009 (data collected 

by RealTimeResearch and by Oregon 

State University for the USFWS 

Westwide Colonial Waterbird Survey). 

The creation of dams in eastern 

Washington is noted as a cause of 

population increases over the past 50 years (Seattle Audubon 2005). 

From FY06 through FY10, WS dispersed an average of 136,680 and killed an 

average of 1,076 California gulls per year. Based on the yearly average, 

anticipated projects, and the stable to positive trend in the population (Sauer et al. 

2011), WS could possibly remove up to 2,500 California gulls per year and not 

impact the distribution, abundance, or population trend of the species. 

Ring-billed Gull Population Impacts

Ryder (1993) in the BNA estimates the North American population of ring-billed 

gulls at 3-4 million. This includes breeding and non-breeding birds. The North 

American breeding population is estimated at 1,700,000 breeders with increasing 

population trends (Kushlan et al. 2002). More recently, Sauer et al. (2011) show a 

stable population trend in WA since 2000. In Washington and along the Columbia 

River corridor, the number of breeding ring-billed gulls was 17,468 birds (8,734 

pairs) in 1977 (Conover 1979). This number increased to 30,606 birds (15,303 

pairs) in 2009 (data collected by RealTimeResearch and by Oregon State 

University for the USFWS Westwide Colonial Waterbird Survey). Ring-billed gulls 

are widely distributed across North America, and populations have increased 

since the mid-1990s in response to increased human-related food sources. 

From FY06 through FY10, WS dispersed an average of 69,074 and killed an 

average of 922 ring-billed gulls annually. Based on the yearly average, anticipated 

Figure 4.3. California Gull Populations 

Trend in BBS Western Region 1968-2009

(Sauer et al. 2011).
Bird Damage Management in Washington - 61

projects, and the stable to positive trend in the WA and nation-wide population, 

WS could possibly remove up to 3,400 ring-billed gulls per year and not impact the 

distribution, abundance, or population trend of the species.

4.4.1.2.3 Cormorants, Herons, and Mergansers

Double-crested Cormorant Population Impacts

Double-crested cormorant populations throughout the Columbia Basin appear to 

be increasing, along with concerns about the impact of these birds to salmonid 

smolt (BRN online). The BBS shows that double-crested cormorant populations in

WA have increased during the last several decades (Sauer et al. 2011). WA WS 

harassed an average of 51,652 double-crested cormorants and killed an average of 

202 per year from FY06 through FY10 for projects associated with this EA.

Based on the yearly average, anticipated projects, and the positive trend in the 

population, WS could possibly remove up to 750 double-crested cormorants per 

year and not impact the distribution, abundance, or population trend of the 

species.

Great Blue Heron Population Impacts

Great blue herons in WA are highly adaptable and largely year round residents 

(Seattle Audubon 2005). Most conflicts with herons occur at fish hatcheries 

statewide and at airports in the Puget Sound area where they pose a threat to 

aviation and public safety. Population estimates for the Puget Sound, Strait of Juan 

de Fuca, and Strait of Georgia include 121 colonies and 4,700 nesting pairs 

(Eissinger 2007); Sauer et al. (2011) shows the population as relatively stable in 

Washington. These numbers likely increase as herons migrate into and through 

the area during the fall and spring migration periods. WS harassed an average of 

3,867 and killed an average of 19 herons per year from FY06 through FY10. 

Harassment occurred primarily at fish hatcheries and hydroelectric facilities, 

while WS take was restricted to airfields. WA WS could take up to 50 great blue 

herons per year (about 0.53% of the estimated breeding population of the Puget 

Sound, because not all birds would be local breeders) and not impact the 

abundance, distribution, or population trend of the species. 

Common Merganser Population Impacts

The estimated average wintering population of mergansers (WDFW groups all 

mergansers together during their surveys) in WA, from 2006 through 2009, was 

7,175 (WDFW 2009). The BBS shows that common merganser populations in WA 

have increased over the last several decades (Sauer et al. 2011). 

WA WS harassed an average of 1,402 common mergansers and killed an average 

of nine annually, from FY06 through FY10. Based on the yearly average, 
Bird Damage Management in Washington - 62

anticipated projects, and the positive trend in the population (Sauer et al. 2011), 

WS could remove up to 200 common mergansers per year, <3% of the wintering 

population (not all common mergansers are taken during the winter) and not 

impact the distribution, abundance, or population trend of the species. 

4.4.1.2.4 Depredation Order Species

Species listed below are included in depredation orders issued by USFWS for the 

protection of agriculture, property and public safety. Agencies and the general 

public are authorized to control depredation by these species on resources 

without a permit under the guidance provided in CFR §21.43 and §21.46.

Brewer’s Blackbird Population Impacts

Partners in Flight estimates that there are 1,700,000 Brewer’s blackbirds in WA

(RMBO 2004) and the BBS shows that the Brewer’s blackbird populations in WA 

are stable (Sauer et al. 2011). WA WS harassed an average of 14,577 and killed an 

average of 1,433 Brewer’s blackbirds per year. WA WS does not anticipate taking,

but could take up to, 10,000 Brewer’s blackbirds per year to protect resources,

approximately 0.6% of the estimated population, and not impact the abundance, 

distribution or trend of the species. 

Red-winged Blackbird Population Impacts

WA WS dispersed an average of 2,358 and killed an average of 2,346 red-winged 

blackbirds between FY06 and FY09. BBS shows that the red-winged blackbird 

population in WA is stable to increasing and Partners in Flight estimates that the 

statewide population is approximately 1,800,000 (RMBO 2004). WA WS does not 

anticipate taking, but could take up to 10,000 red-winged blackbirds, 0.5% of the 

state population, without impacting the abundance, distribution, or trend of the 

species. 

Brown-headed Cowbird Population Impacts

Brown-headed cowbirds are a "brood parasite" that lays eggs in the nests of other 

species. Cowbird eggs hatch faster than other species and the young develop 

faster, often killing the host species' young. They are far more abundant and 

widespread than they were historically, and their parasitic activities can have a 

detrimental impact on other native birds (Seattle Audubon 2005). Partners in 

Flight estimates that the WA population of cowbirds is approximately 670,000

(RMBO 2004) and the BBS shows that the brown-headed blackbird population in 

WA is declining (Sauer et al. 2011). WS harassed an average of 819 and killed an 

average of 2,010 brown-headed cowbirds per year from FY06 through FY10. WA 

WS does not anticipate taking but could take up to 10,000 cowbirds annually, 

approximately 1.5% of the estimated state population, without impacting the 

abundance, distribution, or trend of the species. 
Bird Damage Management in Washington - 63

American Crow Population Impacts

The American crow population in WA is estimated to be approximately 380,000 

(RMBO 2004), and the BBS trend for WA is relatively stable (Sauer et al. 2011). 

WA WS harassed an average of 31,688 and killed an average of 1,834 American 

crows per year for the analysis period. WA WS does not anticipate taking but 

could take up to 2,000 American crows per year, 0.5% of the estimated state 

population, without impacting the species abundance, distribution, or trend. 

Northwestern Crow Population Impacts

Northwestern crow populations in WA are healthy with an estimated population 

of 5,000 individuals (RMBO 2004). WA WS dispersed an average of 1,105 and 

lethally removed and average of 81 northwestern crows per year from FY06

through FY10. BBS trend information indicates that northwestern crow 

populations have decreased substantially since 1966 in WA, but the Western BBS 

region population has remained relatively stable since 1966 (Sauer et al. 2011). 

WS anticipates taking up to 100 Northwestern crows per year, 2% of the 

population, and would not impact the species abundance, distribution, or trend. 

4.4.1.2.5 Passerine Species

Common Raven Population Impacts

Common ravens in WA show an increasing population trend (Sauer et al. 2011). 

According to Partners in Flight, the breeding population of common ravens in 

Washington is approximately 21,000. WS dispersed an average of 4,021 and killed 

an average of 25 ravens per year. WA WS could take up to 250 ravens per year

(1% of the estimated breeding WA population) without impacting the species 

abundance, distribution, or trend. 

Northern Flicker Population Impacts

Northern flickers are abundant and widespread throughout their range (Seattle 

Audubon 2005). Partners in Flight estimates that the WA northern flicker 

population is approximately 190,000. The BBS trend shows a relatively stable 

population trend for the species (Sauer et al. 2011). WS killed an average of 45 

flickers per year for the protection of property. WA WS could take up to 100

flickers per year and not affect the distribution, abundance, or trend of the species. 

House Finch Population Impacts

House finches are common predators of fruit crops in WA and are often associated 

with starlings in agricultural depredation situations. Partners in Flight estimates 

that the WA population of house finches is approximately 520,000 (RMBO 2004). 

The BBS shows an increasing population trend during the last few decades (Sauer 

et al. 2011). WA WS took an average of 554 house finches for the protection of 

agriculture. WA WS could take up to 1,300 house finches per year (0.25% of the 
Bird Damage Management in Washington - 64

estimated WA population) and not impact the abundance, distribution, or trend of 

the species. 

American Robin Population Impacts

WA WS has had little take and few encounters with American robin depredation in 

recent years; however, WS received increasing complaints from agricultural 

producers since 2006. WA WS dispersed an average of 127 and lethally removed 

and average of one American robin per year from FY06 through FY10.

The BBS shows an increasing population trend in American robin populations

(Sauer et al. 2011), and Partners in Flights estimates there are 6,200,000 robins in 

Washington (RMBO 2004). WS could take up to 2,000 robins per year, an 

estimated 0.03% of the population, without affecting the abundance, distribution, 

or trend of the species. 

Barn and Cliff Swallow Population Impacts

WA WS was requested to assist state and local agencies with swallow 

management on bridges. This assistance would be in the form of ongoing 

preventative management to eliminate swallow nesting on bridges where safety, 

maintenance, or construction projects are planned. In some cases, nests may be 

constructed and eggs laid prior to WS being able to prevent it. Therefore WS may 

be required to remove barn or cliff swallow nests/eggs. Partners if Flight 

estimates there are more than 1 million and 3 million barn and cliff swallows, 

respectively, in WA (RMBO 2004). WS could remove 500 eggs a year without 

affecting the abundance, distribution, or trend of these species. 

4.4.1.2.6 Raptors

Red-tailed Hawk Population Impacts

The WA red-tailed hawk population is estimated to be 47,000 individuals (RMBO 

2004) and BBS trend data for the species shows that WA has an increasing 

population (Sauer et al. 2011). WA WS harassed an average of 41, relocated an 

average of 12, and killed an average of 10 red-tailed hawks per year for FY06 

through FY10 for the protection of aviation and human safety. WA WS could 

lethally remove up to 30 red-tailed hawks (0.06% of the estimated statewide 

population) per year without impacting the abundance, distribution, or trend of 

the species. 

Bald Eagle Population Impacts

On August 9, 2007 the bald eagle was removed from the federal list of T&E species, 

although it remains protected under the BGEPA and MBTA. The species is a 

federal Species of Concern and a State Sensitive Species. The increasing 

population poses a unique threat for airports that contain or border eagle habitat. 

Eagles are large and generally un-phased by noise once they habituate to an 

airport environment. Harassment is limited in its effectiveness, increasing the 
Bird Damage Management in Washington - 65

need to translocate bald eagles to decrease the threat to aviation. Under permits

from USFWS, WA WS harassed an average of 37 bald eagles per year may trap and 

translocate bald eagles from an airfield to protect human health and safety; no 

eagles were killed by WS during this analysis period. WA WS may translocate as 

many eagles as necessary and permitted to protect public safety on airfields, while 

also protecting eagles from being killed by aircraft. Translocation and/or 

harassment of bald eagles at airfields would not negatively impact the abundance, 

distribution, or trend of the species.

4.4.1.2.7 Shorebirds

Killdeer Population Impacts

Killdeer (Charadrius vociferous) are common year-round in WA (Larsen et al. 

2004). The BBS trend for killdeer in WA shows an oscillating, but relatively stable 

population (Sauer et al. 2011). WA WS harassed an average of 105 and killed an 

average of 25 killdeer per year for the protection of aviation and human safety. 

WA WS could take up to 50 killdeer per year without affecting the species’ 

abundance, distribution, or trend. 

4.4.1.2.8 Invasive Species 

An invasive species is not protected by state or federal regulation and defined 

under EO 13112 as a species that is non-native (or exotic) to the ecosystem under 

consideration and whose introduction causes, or is likely to cause, economic or 

environmental harm, or harm to human health. Invasive species such as the 

European starling, English sparrow, and feral pigeon commonly occur throughout 

WA, and other species are located sporadically and in smaller numbers across the 

state.

Feral Pigeon, English Sparrow, Eurasian Collared-Dove, and European 

Starling Population Impacts

Feral pigeons, English sparrows, Eurasian collared-doves, and European starlings 

are listed as predatory birds under WA state law. Other less common introduced, 

feral, or invasive species in WA include mute swans (Cygnus olor) and monk 

parakeets (Myiopsitta monachus). All these species may be trapped or killed year 

round without a hunting license or when threatening human safety or causing 

property damage with no limits on take or requirement to report take (WAC 232-

12-005, RCW 77.36.030). None of the species listed above are federally protected 

and the birds, their eggs, and nests may be removed by any legal method.

Feral pigeon BBS trend data for WA indicate that their numbers are increasing 

(Sauer et al. 2011) with a current estimated population of 800,000 (RMBO 2004). 

WA WS harassed an average of 7,808 and killed an average of 9,101 feral pigeons 

per year from FY06 through FY10. As an invasive species, WS could remove as 

many feral pigeons as necessary to reduce damages to resources, and will conduct 
Bird Damage Management in Washington - 66

activities as funding allows, but is not proposing any attempt to extirpate the 

species under this EA.

English sparrows, also called house sparrows, are estimated to number 1,200,000 

in WA (RMBO 2004). The BBS trend shows English sparrow populations remain 

relatively stable with annual variations in populations in WA (Sauer et al. 2011). 

WA WS dispersed an average of 213 and killed an average of 852 English sparrows 

per year. As an invasive species, WS could remove as many English sparrows as 

necessary to damages to resources, and will conduct activities as funding allows, 

but is not proposing any attempt to extirpate the species under this EA. 

Eurasian collared-doves, a native species of south Asia, are a recent arrival in WA 

and are highly adaptable to agricultural and suburban habitats (Seattle Audubon 

2005). The BBS trend shows Eurasian collared-doves populations are 

exponentially increasing in the Western BBS Region (Sauer et al. 2011). WS is

receiving requests for assistance with this species for the protection of agricultural 

operations, primarily at dairies where the birds are consuming and contaminating 

feed products. As an invasive species, WS could remove as many Eurasian 

collared-doves as necessary to alleviate threats to resources, and will conduct 

activities as funding allows, but is not proposing any attempt to extirpate the 

species under this EA.

The nationwide European starling population has been estimated to exceed 200

million (National Geographic 2006) and WA has an estimated population of 

approximately 3,200,000 birds (RMBO 2004). BBS trend data indicate that 

starling numbers have increased in WA over that last few decades (Sauer et al. 

2011). WA WS dispersed an average of 509,481 and killed an average of 425,872

European starlings annually from FY06 through FY10. As an invasive species, WS 

could remove as many European starlings as necessary to control predation on 

resources, and will conduct activities as funding allows, but is not proposing any 

attempt to extirpate the species under this EA. 

As non-native, invasive species, and because of their predatory impacts and 

competition with native birds, these species are considered by many wildlife 

biologists and ornithologists to be an undesirable component of North American 

wild and native ecosystems. Any reduction in these species in WA, even to the 

extent of complete eradication, could be considered beneficial to the human 

environment. 

4.4.1.3 Humaneness of Methods

The issue of humaneness, as it relates to the killing or capturing of wildlife is an 

important but very complex concept. Kellert and Berry (1980), in a survey of 

American attitudes toward animals, related that 58% of their respondents,”...care 

more about the suffering of individual animals...than they do about species population 

levels.” Schmidt (1989) indicated that vertebrate pest control for societal benefits 

could be compatible with animal welfare concerns, if “...the reduction of pain, 

suffering, and unnecessary death is incorporated in the decision making process.” 
Bird Damage Management in Washington - 67

Suffering has been described as a “...highly unpleasant emotional response usually 

associated with pain and distress.” However, suffering “...can occur without pain...,” 

and “...pain can occur without suffering...” (American Veterinary Medical Association 

(AVMA) 2001). Because suffering carries with it the implication of a time frame, a 

case could be made for “...little or no suffering where death comes immediately...” 

[California Department of Fish and Game (CDFG) 2004], such as with shooting.

Defining pain as a component of humaneness may be a greater challenge than that 

of suffering. Altered physiology and behavior can be indicators of pain, and 

identifying the causes that elicit pain responses in humans would “...probably are 

causes for pain in other animals...” (AVMA 2001). However, pain experienced by 

individual animals probably ranges from little or no pain to significant pain (CDFG 

2004). Some WS damage management methods may thus cause varying degrees of 

pain in different animal species for varying time frames. 

Pain and suffering, as they relate to a review of WS BDM methods to capture 

animals, have professional and lay points of arbitration. Wildlife managers and the 

public would be better served to recognize the complexity of defining suffering, 

since “...neither medical nor veterinary curricula address suffering or its relief ...”

(CDFG 2004). 

Thus, the decision-making process involves tradeoffs between the above aspects of 

pain and humaneness. An objective analysis of this issue must consider not only the 

welfare of wild animals but also the welfare of pets or humans, if damage 

management methods were not used. Therefore, humaneness, in part, appears to be 

a person’s experience with the problem wildlife and their perception of harm or 

pain inflicted on an animal, and people may perceive the humaneness of an action 

differently. The challenge in coping with this issue is how to achieve the least 

amount of suffering with the constraints imposed by current technology and 

funding. 

BDM methods under this alternative could be viewed by some persons as inhumane. 

However, the methods used under this alternative comply with WS SOPs, AVMA 

guidelines, and state and federal regulations which are designed to maximize 

humaneness and reduce the perceived stress and trauma associated with wildlife 

management control actions. 

WS only uses EPA registered and approved pesticides and WS personnel are 

experienced, professional and humane in their use of management methods. Under 

this alternative, target birds would be killed by experienced WS personnel using the 

best and most appropriate method(s) available. Some people may perceive these 

methods as inhumane because they oppose all lethal methods of damage 

management. 

WS has improved the selectivity of management devices through research and is 

striving to bring new findings and products into practical use. Until new findings 

and products are found practical, a certain amount of animal suffering could occur 
Bird Damage Management in Washington - 68

when some methods are used in those situations when nonlethal damage 

management methods are not practical or effective. WA WS personnel are 

experienced and professional in their use of management methods so that they are 

as humane as possible under the constraints of current technology, workforce, and 

funding. 

4.4.1.4 Effectiveness of BDM Program in Washington

Effectiveness of the WA BDM program is defined as the timely and successful 

application of safe and selective methods to prevent and alleviate damage caused by 

birds. Under the current program, all methods are as selective and effective as 

possible, in conformance with the WS Decision Model (Slate et al. 1992), WS 

Directives, and state and federal laws. By using the Decision Model, WS implements 

the most selective and efficient methods to resolve damage situations. Under 

Alternative 1, WS would have the fullest array of BDM methods at its professional 

discretion at all times. In situations where human safety is at risk, immediate and 

decisive action may be required to prevent injury or death. Alternative 1 would 

allow the implementation of lethal removal to resolve immediate risks to human 

health and safety when nonlethal control is inadequate. Should there not be an 

immediate threat to human health and safety, WS would give preference to 

nonlethal methods even though lethal removal may become necessary. Therefore, 

Alternative 1 provides for a highly effective approach to insuring human health and 

safety and resolving BDM problems.

4.4.2 Alternative 2: Implement All Nonlethal Methods Before Using Lethal Methods

Alternative 2 requires that all nonlethal methods be implemented, regardless of 

practicality or effectiveness, before any lethal methods are used by WS. With this 

alternative, WS would be required to implement the entirety of nonlethal methods prior 

to implementing lethal management. WS does not propose to implement any method 

that could adversely affect non-target or ESA-listed species, violate state or federal laws,

or considered unsafe. Anyone requesting TA would be provided information regarding 

the use of practical and effective nonlethal and lethal techniques. The WS Decision 

Model (Slate et al. 1992) could be used under this alternative, however the most 

effective and practical method(s) may not always be applied under this alternative. 

4.4.2.1 Effects of Methods on Non-target and ESA-listed Species

As with Alternative 1, WS would have no effect on non-target or ESA-listed species. 

However, non-WS individuals may choose to implement control measures 

themselves, because they do not want damage to continue while waiting for all the 

nonlethal methods to be exhausted by WS. Use of methods by untrained individuals 

could negatively affect non-target and ESA-listed species, because untrained 

persons may apply methods in an unsafe or illegal manner. 

4.4.2.2 Effect of Methods on Populations of Target Species

As with Alternative 1, WS would have no adverse effect on target species. However, 

non-WS individuals may choose to implement control measures themselves, 
Bird Damage Management in Washington - 69

because they do not want damage to continue while waiting for all the nonlethal 

methods to be exhausted by WS. Use of methods by untrained individuals could 

negatively affect some target species because untrained persons may apply methods 

in an unsafe or illegal manner. 

4.4.2.3 Humaneness of Methods

The methods used by WS are equally humane under Alternatives 1 and 2. 

Individuals requesting immediate assistance with damage situations may not be 

willing to wait for WS to exhaust the use of nonlethal methods before applying lethal 

control. This could result in private individuals taking action against actual or 

perceived damaging species. WS would continue to only recommend and apply the 

most selective and humane methods possible, but the humaneness of their 

application by untrained individuals cannot be controlled. This alternative may be 

less humane than Alternative 1 depending on the application of method(s) by 

untrained non-WS entities.

4.4.2.4 Effectiveness of BDM Program in Washington

Effectiveness of the WA BDM program is defined as the timely and successful 

application of safe and selective methods to prevent and alleviate damage caused by 

birds. Alternative 2 requires that all nonlethal methods be implemented regardless 

of practicality or effectiveness before any lethal methods are used by WS. This could 

exacerbate the damage problem by allowing more damage to accrue if the nonlethal 

methods are ineffective in resolving the problem. In addition, more depredating 

birds may be attracted to the area or their numbers may increase through 

reproduction during the time that nonlethal methods are being attempted. This 

could later result in the necessity to lethally remove more birds than if lethal 

removal had been implemented according to the WS Decision Model used in 

Alternative 1. Deferring the use of lethal removal while all other options are 

exhausted (regardless of effectiveness) could increase the time necessary to resolve 

the problem and allow an increase in the number of damaging birds, further 

reducing the overall effectiveness under Alternative 2. Therefore, BDM under 

Alternative 2 would likely be less effective than the Proposed Alternative. 

4.4.3 Alternative 3: Technical Assistance BDM Program Only 

Alternative 3 would require WS to provide only TA to resolve bird damage problems.

4.4.3.1 Effects of Methods on Non-target and ESA-listed Species

Under this Alternative, WS would have no direct effect on non-target and ESA-listed 

species. While WS can analyze its own implementation of BDM methods, the effects 

of implementation of the same methods by non-WS individuals cannot be fully 

anticipated or controlled. The inability to fully predict potential effects from a nonWS entity implementing BDM makes Alternative 3 a less responsible choice. The 

absence of operational BDM by WS may increase the use of illegal or inappropriate 

methods by individuals when they do not receive WS operational BDM assistance. 

While WS cannot provide operational BDM under this alternative, requestors could 
Bird Damage Management in Washington - 70

obtain authorization to use lethal control through USFWS or WDFW. Unintentional 

harassment and take of non-target and ESA-listed species by non-WS personnel 

could be greater than or less than those anticipated under Alternative 1 depending 

on the extent of management and the amount of expertise with which BDM is 

implemented. Even some nonlethal methods, if applied improperly, can have 

adverse sub-lethal or lethal effects and be detrimental to sensitive species. The use 

of lethal methods by non-WS personnel could result in increased take of non-target 

species, including ESA and state-listed species. The application of BDM methods by

untrained personnel would likely result in a greater potential impact to non-target 

and ESA listed species than the BDM proposed under Alternative 1.

4.4.3.2 Effects of Methods on Populations of Target Species

WS would have no direct effect on target species populations under Alternative 3. 

The same discussion (section 4.4.2.2) of effects regarding non-target and ESA-listed 

species applies to target populations. 

4.4.3.3 Humaneness of Methods

The methods recommended by WS, if properly applied, are equally humane under 

Alternatives 1, 2, and 3. WS would continue to only recommend the most selective 

and humane methods possible, but the humaneness of their application by 

untrained individuals cannot be controlled. This Alternative may be less humane 

than Alternative 1 or 2 depending on how the methods are used.

4.4.3.4 Effectiveness of BDM Program in Washington

Effectiveness of the WA BDM program is defined as the timely and successful 

application of safe and selective methods to prevent and alleviate damage caused by 

birds. WS would continue to recommend the most selective, effective, and humane 

methods possible, but the application of these methods by untrained individuals 

cannot be controlled, and these methods would likely be applied with less expertise 

than if WS provided operational assistance directly. Therefore, BDM under 

Alternative 3 would likely be less effective than under the Proposed Alternative. 

4.4.4 Alternative 4: No WS Program

Under Alternative 4, WS would not administer or conduct a BDM program in WA. 

Taking no WS action could reasonably be expected to present be the most risk to 

humans and target and non-target species, and be the least effective of all of the 

alternatives examined in this EA. WS would not provide TA or operational BDM. 

Some entities are required by law to conduct wildlife damage management. For 

example, the FAA requires certificated airports to implement measures to alleviate or 

eliminate wildlife hazards to air carrier operations (14 CFR 139.337(d)). Landfills 

“demonstrate that the units are designed and operated so that the MSWLF unit does not 

pose a bird hazard to aircraft” (WAC 173-351-130) and “must prevent or control on-site 

populations of disease vectors” (WAC 173-351-200. In the absence of WS, the USFWS 

and WDFW may continue to issue Depredation Permits directly to airports and other 
Bird Damage Management in Washington - 71

property owners. Airports would still be required to perform wildlife hazard 

management per FAA guidelines, without any assistance or recommendations from WS. 

Airports and other entities could contract with non-WS wildlife control sources or 

conduct BDM on their own without oversight or recommendations from WS. 

4.4.4.1 Effect of Methods on Non-target and ESA-listed Species

Under this alternative, WS would not affect non-target and ESA-listed species. WS 

would offer no TA or operational damage management assistance on practical and 

effective methods for BDM. It is possible that frustration caused by an inability to 

reduce damages could lead to the misapplication of methods causing negative 

effects to non-target and ESA-listed species. The effect of non-WS personnel 

implementing BDM is unknown, but would likely be more adverse to non-target and 

ESA listed species than the Proposed Alternative.

4.4.4.2 Effect of Methods on Populations of Target Species

Under this Alternative, WS would not affect target species. WS would offer no TA or 

operational BDM regarding practical, effective, and safe methods for resolving bird 

damage. Airports, landfills, and other entities would still be required to perform 

wildlife hazard management per FAA, WAC, and other state regulations without any 

assistance or recommendations from WS. Those experiencing bird damage or 

potential bird damage could contract with non-WS wildlife control sources or 

conduct BDM on their own, without oversight or recommendations from WS. It is 

possible that frustration caused by an inability of individuals to reduce losses could 

lead to the misapplication of methods. The effect of non-WS personnel 

implementing BDM is unknown, but would likely be more adverse to target species 

than the Proposed Alternative. 

4.4.4.3 Humaneness of Methods

Under this Alternative, WS could not recommend or provide practical, effective, and 

safe methods for reducing bird damage and threats to human health and safety. As 

such, WS could not affect application of methods or the humaneness of methods use. 

The humaneness of methods applied by untrained individuals would be unknown. 

Frustrated resource owners could implement methods not usually recommended by 

WS, use BDM methods incorrectly, or attempt illegal methods. As such, this 

Alternative would likely be less humane than Alternative 1.

4.4.4.4 Effectiveness of BDM Program in Washington

Under the No WS Program Alternative, WS would not be available to provide Agency 

expertise in resolving bird damage problems, either TA or operational assistance. 

Those needing assistance would likely turn to other wildlife agencies, private pest 

control operators, or attempt to resolve problems themselves. While some may find 

effective help and advice, others may not. As such, this Alternative would likely be 

less effective in resolving bird damage problems than Alternative 1. 
Bird Damage Management in Washington - 72

4.5 Cumulative Impacts

Cumulative impacts, as defined by CEQ (40 CFR 1508.7), are impacts on the environment 

that result from the incremental impact of an action when added to other past, present, and 

reasonably foreseeable future actions, regardless of what agency (federal or non-federal) 

or person undertakes such other actions. Cumulative impacts may result from individually 

minor, but collectively significant, actions taking place over time. WS accounts for the 

majority of migratory bird take under depredation permits issued by the USFWS. The 

primary purpose of this EA was to combine WS BDM activities into one EA and analyze take 

comprehensively under one EA. 

Because WS is the primary organization in WA reducing bird damage and taking migratory 

birds while conducting those activities, it follows that other USFWS permitted take would 

be less. WS obtained 

USFWS depredation report 

information for all non-WS 

permitted take of 

migratory birds from the 

USFWS from 2006 through

2010. USFWS records data 

on a calendar year basis, 

whereas WS records data 

on a FY basis. WS 

compared the average 

annual non-WS take 

against the average WS 

annual take for the 

reporting period (Table 

4.1). Non-WS take is lower

and does not result in any 

significant impacts to the 

human environment when 

combined with WS take. 

As analyzed in this EA, WS 

BDM activities and the methods used or recommended by WA WS will have no cumulative 

adverse effects on target, non-target, or ESA-listed wildlife species. 

4.6 Summary

No significant cumulative environmental impacts are expected from the Proposed 

Alternative in this EA (Table 4.2). Under the Proposed Alternative, the lethal removal of 

birds by WS would not have a significant impact on overall bird populations in WA, USFWS 

Region 1, or in the BBS Western Region, but some very localized reductions of some species 

may occur. WS maintains ongoing contact with USFWS and WDFW to ensure local, state, 

and regional knowledge of WS activities and wildlife population trends. 

Species Ave Non-WS 

Take/Year

Ave WS 

Take/Year

 gulls, glaucous-winged 154 3,749

 gulls, california 49 1,076

 gulls, ring-billed 73 922

 finches, house 0 554

 cormorants, double-crested 4 202

 ducks, mallard 90 122

 gulls, herring 3 68

 flicker, northern 4 45

 killdeer 6 25

 ravens, common 1 25

 geese, canada 171 23

 gulls, western 15 20

 herons, great blue 5 19

 ducks, teal, green-winged 11 18

 ducks, gadwall 11 17

 ducks, teal, blue-winged 3 12

 ducks, bufflehead 4 11

 ducks, ring-necked 6 11

 ducks, wigeon, american 1 11

 ducks, northern shoveler 3 10

 hawks, red-tailed 14 10

Table 4.1 Comparison of WS average annual take to that of all other USFWS 

permitted take in WA.
Bird Damage Management in Washington - 73

No risk to public safety is expected when WS’ services are provided to requesting 

individuals under Alternative 1, because only trained and experienced wildlife 

biologists/specialists would conduct and/or recommend BDM activities. There is an 

increased risk to public safety when persons reject WS assistance and recommendations, 

conduct their own BDM (Alternatives 2 and 3), or when no WS operational BDM is 

provided (Alternatives 3 and 4). Although some persons will likely be opposed to WS’ 

participation in BDM activities on public and private lands in WA, the analysis in this EA 

indicates that an adaptive integrated BDM program would not result in significant 

cumulative adverse impacts on the quality of the human environment. 

This EA will be reviewed periodically to assure conformance with current environmental 

regulations and project scope. Substantial changes in the project scope or changes in 

environmental regulations may require revisions and supplementation, or a new EA. 

Alternative 1 Alternative 2 Alternative 3 Alternative 4

(Current 

Program)

(Exhaust Nonlethal) (TA Only) (No WS 

Program)

Effects of Methods on Non-Target and ESAListed Species Low Low to 

Moderate Low to High Low to High

Effects of Methods on Target Species Low Low Low to High Low to High

Humaneness of Methods High High Moderate Low to 

Moderate

Effectiveness of Methods High Low Low Low

Table 4.2. Summary of Environmental Consequences for each issue and alternative analyzed compared 

to the Proposed Alternative (Alternative 1).

Issues
Bird Damage Management in Washington - 74

CHAPTER 5 LIST OF PREPARERS, REVIEWERS, AND PERSONS CONSULTED

5.1 Preparers and Reviewers

Kenneth Gruver, USDA-APHIS-WS, Olympia, Washington

David Hayes, USDA-APHIS-WS, Billings, Montana

Erica McDonald, USDA-APHIS-WS, Olympia, Washington

Laurence M. Schafer, USDA-APHIS-WS, Olympia, Washington

Roger Woodruff, USDA-APHIS-WS, Olympia, Washington 

5.2 Persons Consulted

Rocky Beach, WDFW

Brad Bortner, USFWS

Joe Buchannan, WDFW

Jenny Hoskins, USFWS

Don Kraege, WDFW

Chris Pinney, USACE

Von Pope, Chelan County PUD

Paul Schmidt, USACE

Behr Turner, Grant County PUD
Bird Damage Management in Washington - 75

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Bird Damage Management in Washington - 83

Appendix A

Appendix A Additional Tables and Figures

Table A.1. WS BDM Operations by species and FY, by lethal versus nonlethal.

FY06 FY07 FY08 FY09 FY10

Row Labels Lethal Nonlethal Lethal Nonlethal Lethal Nonlethal Lethal Nonlethal Lethal Nonlethal

Cormorants

PELAGIC 6 27 0 0 1 5 8 349 2 3

DOUBLE-CRESTED 143 42,105 258 25,932 163 74,168 255 64,980 193 51,077

Depredation Order Birds

STARLINGS, EUROPEAN 432,986 687,731 233,988 637,425 711,322 307,952 429,366 387,342 321,699 526,954

MAGPIES, BLACK-BILLED 0 0 1 0 2 0 21 0 24 0

CROWS, NORTHWESTERN 44 1,359 46 2,585 124 703 95 482 98 398

CROWS, AMERICAN 724 33,143 1,137 18,507 1,595 33,256 2,964 41,596 2,748 31,936

COWBIRDS, BROWN-HEADED 270 200 376 2,037 2,505 60 2,859 1,250 4,042 550

BLACKBIRDS, Z-(MIXED SPECIES) 25 3,900 0 0 0 0 0 0 0 0

BLACKBIRDS, YELLOW-HEADED 13 1 2 0 0 0 1 0 0 1

BLACKBIRDS, RED-WINGED 995 0 551 5,446 2,254 1,430 3,852 1,703 4,076 3,213

BLACKBIRDS, BREWER`S 1,896 2,709 1,435 20,245 1,189 14,080 963 18,748 1,680 17,105

Domestic Feral

SPARROWS, HOUSE/ENGLISH 1,677 144 402 616 1,896 248 173 30 110 25

PIGEONS, FERAL (ROCK) 10,716 12,486 7,136 16,020 7,448 4,855 6,724 6,041 7,014 6,105

PARAKEETS, MONK 0 0 0 0 4 7 0 0 0 0

GEESE, FERAL 5 0 0 0 0 0 2 0 0 0

DUCKS, FERAL 46 0 3 1 7 0 0 0 4 0

Ducks

WOOD 0 0 1 0 0 0 0 0 1 19

WIGEON, AMERICAN 3 676 10 1,984 23 433 2 87 15 114

TEAL, GREEN-WINGED 2 141 19 335 46 659 9 282 15 296

TEAL, CINNAMON 0 0 1 8 8 2 0 0 1 14

TEAL, BLUE-WINGED 0 0 9 4 14 2 0 0 38 46

SCAUP, LESSER 0 7 0 0 0 0 0 0 0 0

RING-NECKED 3 179 8 353 27 995 2 186 14 356

NORTHERN SHOVELER 0 9 1 7 36 265 1 3 11 44

NORTHERN PINTAIL 0 0 0 2 0 5 1 46 1 0

MALLARDS 25 1,413 109 2,126 162 1,631 139 1,293 176 1,876

GOLDENEYE, COMMON 0 6,674 0 55 2 734 0 719 0 8
Bird Damage Management in Washington - 84

Appendix A

FY06 FY07 FY08 FY09 FY10

Row Labels Lethal Nonlethal Lethal Nonlethal Lethal Nonlethal Lethal Nonlethal Lethal Nonlethal

Ducks

GOLDENEYE, BARROW`S 0 1 0 0 0 20 0 0 0 0

GADWALL 14 738 18 394 34 652 11 327 10 260

CANVASBACK 0 1 0 0 0 0 0 0 0 0

BUFFLEHEAD 12 8,147 11 7,578 12 11,882 6 9,857 14 1,461

COOTS, AMERICAN 0 26 0 11 0 22 0 21 0 0

Flickers

NORTHERN 3 3 8 5 56 1 59 4 100 4

Geese

WHITE-FRONTED, GREATER 0 0 0 0 0 0 5 975 0 0

SNOW, GREATER 0 0 0 0 1 0 0 0 0 0

CANADA 20 1,811 21 4,827 35 5,882 20 7,290 1,421 16,461

Grebes

WESTERN 0 1 0 0 0 0 0 0 0 641

PIED-BILLED 0 2 0 0 0 0 0 0 0 0

HORNED 0 0 0 1 0 0 0 0 0 0

(OTHER) 0 6 0 0 0 0 0 0 0 0

Gulls

WESTERN 38 509 4 1 2 1 46 5,361 12 131

RING-BILLED 773 55,018 779 96,865 1,278 98,395 748 45,971 1,034 49,120

MEW 0 0 0 0 4 741 0 0 2 15

HERRING 56 30,037 43 10,533 34 8,829 159 2,158 50 1,347

GLAUCOUS-WINGED 3,931 557,378 3,287 92,983 5,032 213,437 3,874 812,664 2,517 253,368

GLAUCOUS 0 2 0 0 0 0 0 0 0 4

CALIFORNIA 566 135,272 1,323 54,213 1,307 126,822 829 188,829 1,355 178,265

BONAPARTE`S 0 3 0 0 0 0 0 0 0 0

Cranes and Herons

CRANES, SANDHILL 0 0 0 0 0 0 0 0 0 250

HERONS, GREEN 0 1 0 0 0 23 0 0 0 3

HERONS, GREAT BLUE 0 3,725 33 3,445 30 5,919 16 3,455 17 2,792

Kingfisher

BELTED 0 0 0 70 0 37 0 0 0 0

(ALL) 1 1,776 0 0 0 0 0 0 0 0
Bird Damage Management in Washington - 85

Appendix A

FY06 FY07 FY08 FY09 FY10

Row Labels Lethal Nonlethal Lethal Nonlethal Lethal Nonlethal Lethal Nonlethal Lethal Nonlethal

Mergansers

HOODED 1 1,029 3 876 3 3,315 0 4,029 1 638

COMMON 6 633 3 1,340 16 4,326 12 434 8 278

Passerines

WAXWINGS, CEDAR 0 0 0 1 0 0 0 0 0 0

ROBINS, AMERICAN 0 0 0 29 2 100 1 440 0 75

OTHER SONG BIRDS 0 6 0 0 0 0 0 0 0 0

MEADOWLARKS, WESTERN 0 0 0 14 0 0 0 0 0 0

FINCHES, PURPLE 1 0 0 0 0 0 0 0 0 3

FINCHES, HOUSE 530 0 1,265 34 953 52 24 0 0 0

DOVES, MOURNING 0 0 0 0 3 1 1 0 0 0

Pelicans

AMERICAN WHITE 0 0 0 0 0 0 0 462 0 19

Raptors

VULTURES, TURKEY 0 0 0 0 12 38 2 7 3 19

SHRIKES (ALL) 0 0 0 0 0 1 0 0 0 0

OWLS, SHORT-EARED 0 0 0 0 8 7 0 0 0 0

OWLS, GREAT HORNED 0 0 0 0 0 0 0 10 0 2

OWLS, COMMON BARN 0 1 0 0 0 4 0 7 0 0

OSPREYS 0 1 0 0 0 1 0 0 0 0

HAWKS, ROUGH-LEGGED 0 0 0 0 9 23 14 32 0 15

HAWKS, RED-TAILED 0 4 0 19 30 78 13 89 5 78

HAWKS, HARRIER, NORTHERN 0 1 0 0 20 27 11 7 15 47

HAWKS, COOPER`S 0 12 0 2 0 4 0 3 0 2

FALCONS, MERLIN 0 0 0 0 0 0 0 0 0 1

FALCONS, AMERICAN KESTREL 0 6 6 12 1 6 3 7 3 8

EAGLES, BALD 0 0 0 0 0 29 0 93 0 65

Ravens 

RAVENS, COMMON 83 11,538 3 379 5 87 10 3,091 24 5,012

Shorebirds

TURNSTONES, RUDDY 0 0 0 0 0 300 0 1,550 0 0

SNIPES, COMMON 0 0 0 0 0 0 0 0 1 4

PLOVERS, BLACK-BELLIED 0 0 5 195 9 78 2 67 8 412

KILLDEERS 13 138 68 98 16 85 5 18 24 186
Bird Damage Management in Washington - 86

Appendix A

FY06 FY07 FY08 FY09 FY10

Row Labels Lethal Nonlethal Lethal Nonlethal Lethal Nonlethal Lethal Nonlethal Lethal Nonlethal

Shorebirds (cont.)

DUNLINS 0 0 0 0 5 100 0 0 0 200

Swallows

VIOLET-GREEN 0 0 0 0 0 100 0 0 0 0

BARN 0 0 18 50 0 0 0 100 15 5

Swans

TUNDRA 0 0 0 0 0 0 0 0 5 397

MUTE 0 0 0 0 0 5 0 0 0 0

Terns

FORSTER`S 0 135 0 97 0 3,090 0 575 0 0

CASPIAN 0 5,488 0 3,433 0 35,284 0 8,023 0 9,103

Upland

TURKEYS, WILD 0 0 0 0 0 0 0 0 4 0

QUAIL (ALL) 0 0 0 1 0 0 0 1 0 0

PHEASANTS, RING-NECKED 0 0 0 0 1 0 0 0 0 0
Bird Damage Management in Washington - 87

Appendix B

Appendix B Authorities and Compliance

Wildlife Services. WS’ activities are conducted at the request of and in cooperation with other 

federal, state, and local agencies, private organizations, and individuals. WS is directed by the U.S. 

Congress to protect American agriculture, property, natural resources and human health and safety 

from damage associated with wildlife (Act of March 2, 1931, as amended (46 Stat. 1486; 7 United 

States Code (USC). 426-426c). “Wildlife damage management” is defined as, the reduction or 

alleviation of damage or other problems caused by, or related to, the presence of wildlife, and it is an 

integral component of wildlife management (Leopold 1933, Conover 2002). 

United States Fish and Wildlife Service. The USFWS is the primary federal agency responsible for 

conserving, protecting, and enhancing the nation’s fish and wildlife resources and their habitats. 

The USFWS mission is to conserve, protect, and enhance fish and wildlife and their habitats for the 

continuing benefit of the American people. Responsibilities are shared with other federal, state, 

tribal, and local entities; however, the USFWS has specific responsibilities for endangered species, 

migratory birds, inter-jurisdictional fish, and certain marine mammals, as well as for lands and 

waters they administer for the management and protection of these resources.

The USFWS regulates the taking of migratory birds under the four bilateral migratory bird treaties 

the United States entered into with Great Britain (for Canada), Mexico, Japan, and Russia. 

Regulations allowing the take of migratory birds are authorized by the MBTA (16 U.S.C. Sec’s. 703 -

711), and the Fish and Wildlife Improvement Act of 1978 (16 U.S.C. Sec. 712). The Acts authorize 

and direct the Secretary of the Interior to allow hunting, taking, and killing of migratory birds 

subject to the provisions of, and in order to carry out the purposes of, the four migratory bird 

treaties.

Federal Aviation Administration. The FAA’s authority for managing wildlife hazards at airports is 

based on 14 CFR, Part 139.337. The FAA is the federal agency responsible for developing and 

enforcing air transportation safety regulations and is authorized to reduce wildlife hazards at 

commercial and non-commercial airports. Many of these regulations are codified in the Federal 

Aviation Regulations (FARs). The FAA is responsible for setting and enforcing the FARs and policies 

to enhance public safety. For commercial airports, 14CFR, Part 139.337 (Wildlife Hazard 

Management) directs the airport sponsor to conduct a wildlife hazard assessment if an air carrier 

aircraft experiences multiple wildlife strikes or an air carrier aircraft experiences substantial 

damage from striking wildlife. At non-commercial airports, the FAA also expects that the airport be 

aware of wildlife hazards in and around their airport and take corrective action if warranted; the 

FAA uses Advisory Circular 150/5200-33B to guide their decision making process. 

The FAA is empowered to issue airport operation certificates to airports serving air carriers, and to 

establish minimum safety standards for the operation of airports. Some of these regulations and 

polices directly involved the management of wildlife and wildlife hazards on and/or near airports. 

Under FAR 139.337, Wildlife Hazard Management, an airport is required to conduct a Wildlife 

Hazard Assessment and a Wildlife Hazard Management Plan when specific wildlife event(s) occur. 

Under the FAA/WS MOU, the WS program supports all of the requirements contained in FAR 

139.337. FAA CertAlert No. 97-02 further clarifies the roles of, and relationships between, the FAA 

and WS with regards to wildlife hazards on or near airports.

Washington Department of Fish and Wildlife. WDFW’s authority for managing wildlife in the state of 

Washington is based on Title 77 of the Revised Code of Washington (RCW). 
Bird Damage Management in Washington - 88

Appendix B

Washington State Department of Transportation (WSDOT). WSDOT is a department within the 

government of WA responsible for the steward of a large and robust transportation system, and for 

ensuring that people and goods move safely and efficiently. In addition to building, maintaining, 

and operating the state highway system, WSDOT is responsible for the state ferry system, and 

works in partnership with others to maintain and improve local roads, railroads, airports, and 

multi-modal alternatives to driving.

Compliance with Federal Laws, Executive Orders and Regulations

National Environmental Policy Act. All federal actions are subject to NEPA (Public Law 91-190, 42 

U.S.C. 4321 et seq.). WS and the USFWS follow CEQ regulations implementing NEPA (40 CFR 1500 

et seq.), USDA (7 CFR 1b), and WS follows the APHIS Implementing Guidelines (7 CFR 372) as a part

of the decision-making process. These laws, regulations, and guidelines generally outline five broad 

types of activities to be accomplished as part of any project: public involvement, analysis, 

documentation, implementation, and monitoring. NEPA also sets forth the requirement that all 

major federal actions be evaluated in terms of their potential to significantly affect the quality of the 

human environment for the purpose of avoiding or, where possible, mitigating and minimizing 

adverse impacts. Federal activities affecting the physical and biological environment are regulated 

in part by CEQ through regulations in 40 CFR, Parts 1500-1508. In accordance with CEQ and USDA 

regulations, APHIS Guidelines Concerning Implementation of NEPA Procedures, as published in the 

Federal Register (44 CFR 50381-50384) provide guidance to APHIS regarding the NEPA process.

Pursuant to NEPA and CEQ regulations, this EA documents the analysis of a proposed program, 

informs decision-makers and the public of reasonable alternatives capable of avoiding or 

minimizing adverse impacts, and serves as a decision-aiding mechanism to ensure that the policies 

and goals of NEPA are infused into federal agency actions. This EA was prepared by integrating as 

many of the natural and social sciences as warranted, based on the potential effects of the proposed 

action. The direct, indirect, and cumulative impacts of the proposed action are analyzed.

Endangered Species Act. Under the ESA, all federal agencies are charged with a responsibility to 

conserve endangered and threatened species and to utilize their authorities in furtherance of the 

purposes of the ESA (Sec.2(c)). WS conducts Section 7 consultations with the USFWS to utilize the 

expertise of the USFWS to ensure that, "Any action authorized, funded or carried out by such an 

agency . . . is not likely to jeopardize the continued existence of any endangered or threatened species . 

. ." (Sec.7 (a) (2)). WS conducts formal Section 7 Consultations with the USFWS at the national level 

(USDI 1992) and consultations with the USFWS at the local level as appropriate.

Migratory Bird Treaty Act of 1918 (16 U.S.C. 703-711; 40 Stat. 755), as amended. The MBTA provides 

the USFWS regulatory authority to protect species of birds that migrate outside the United States. 

The law prohibits any "take" of these species by private entities, except as permitted by the USFWS; 

therefore the USFWS issues permits to private entities for reducing bird damage (50 CFR 21.41). 

WS provides on-site assessments for persons experiencing migratory bird damage to obtain 

information on which to base damage management recommendations. Damage management 

recommendations could be in the form of TA or operational assistance. In severe cases of bird 

damage, WS provides recommendations to the USFWS for the issuance of depredation permits to 

private entities. Starlings, pigeons, house sparrows and domestic waterfowl are not classified as 

protected migratory birds and therefore have no protection under the MBTA. USFWS depredation 

permits are also not required for “yellow-headed, red-winged, and Brewer’s blackbirds, cowbirds, 

all grackles, crows (except Mexican crows), and magpies found committing or about to commit 

depredation upon ornamental or shade trees, agricultural crops, livestock, or wildlife, or when 
Bird Damage Management in Washington - 89

Appendix B

concentrated in such numbers and manner as to constitute a health hazard or other nuisance” (50 

CFR 21.43). 

Bald and Golden Eagle Protection Act (BGEPA) (16 U.S.C. §§ 668-668d, June 8, 1940, as amended 1959, 

1962, 1972, and 1978). The BGEPA prohibits the taking or possession of and commerce in bald and 

golden eagles, with limited exceptions. Take includes pursue, shoot, shoot at, poison, wound, kill, 

capture, trap, collect, molest or disturb. Transport includes convey or carry by any means; also 

deliver or receive for conveyance. If compatible with the preservation of bald and golden eagles, 

the Secretary of the Interior may issue regulations authorizing the taking, possession and 

transportation of these eagles for scientific or exhibition purposes, for religious purposes of Indian 

tribes or for the protection of wildlife, agricultural or other interests. Bald eagles may not be taken 

for any purpose unless the Secretary issues a permit prior to the taking.

National Historical Preservation Act (NHPA) of 1966 as amended. The NHPA and its implementing 

regulations (CFR 36, 800) require federal agencies to initiate the section 106 process if an agency 

determines that the agency’s actions are undertakings as defined in Sec. 800.16(y) and, if so, 

whether it is a type of activity that has the potential to cause effects on historic properties. If the 

undertaking is a type of activity that does not have the potential to cause effects on historic 

properties, assuming such historic properties were present, the agency official has no further 

obligations under section 106. Each of the bird damage management methods described in this EA 

that might be used operationally by WS does not cause major ground disturbance, does not cause 

any physical destruction or damage to property, does not cause any alterations of property, wildlife 

habitat, or landscapes, and does not involve the sale, lease, or transfer of ownership of any 

property. In general, such methods also do not have the potential to introduce visual, atmospheric, 

or audible elements to areas in which they are used that could result in effects on the character or 

use of historic properties. Therefore, the methods that would be used by WS under the proposed 

action are not generally the types of activities that would have the potential to affect historic 

properties. If an individual activity with the potential to affect historic resources is planned under 

an alternative selected as a result of a decision on this EA, then site-specific consultation as 

required by Section 106 of the NHPA would be conducted as necessary.

Noise-making methods such as propane exploders, pyrotechnics, or firearms that are used at or in 

close proximity to historic or cultural sites for the purposes of hazing or removing nuisance birds 

have the potential for audible effects on the use and enjoyment of a historic property. However, 

such methods would only be used at a historic site at the request of the owner or manager of the 

site to resolve a damage or nuisance problem, which means such use would be to benefit the 

historic property. A built-in mitigating factor for this issue is that virtually all of the methods 

involved would only have temporary effects on the audible nature of a site and can be ended at any 

time to restore the audible qualities of such sites to their original condition with no further adverse 

effects. Site-specific consultation as required by Section 106 of the NHPA would be conducted as 

necessary in those types of situations.

Native American Graves Protection and Repatriation Act. The Native American Graves Protection 

and Repatriation Act requires federal agencies to notify the Secretary of the Department that 

manages the federal lands upon the discovery of Native American cultural items on federal or tribal 

lands. Federal projects would discontinue work until a reasonable effort has been made to protect 

the items and the proper authority has been notified.
Bird Damage Management in Washington - 90

Appendix B

Occupational Safety and Health Act of 1970. The OSHA of 1970 and its supplementing regulations 

(29CFR1910) on sanitation standards state that "Every enclosed workplace shall be so constructed, 

equipped, and maintained, so far as reasonably practical, as to prevent the entrance or harborage of 

rodents, insects, and other vermin. A continuing and effective extermination program shall be 

instituted where their presence is detected." This standard includes birds that may cause safety 

and health concerns at workplaces.

Environmental Justice and Executive Order 12898 - Federal Actions to Address Environmental Justice 

in Minority Populations and Low-Income Populations. Environmental Justice has been defined as the 

pursuit of equal justice and equal protection under the law for all environmental statutes and 

regulations without discrimination based on race, ethnicity, or socioeconomic status. Executive 

Order 12898 requires Federal agencies to make Environmental Justice part of their mission, and to 

identify and address disproportionately high and adverse human health and environmental effects 

of Federal programs, policies and activities on minority and low-income persons or populations. A 

critical goal of Executive Order 12898 is to improve the scientific basis for decision-making by 

conducting assessments that identify and prioritize environmental health risks and procedures for 

risk reduction. Environmental Justice is a priority within USDA, APHIS, and WS. APHIS plans to 

implement Executive Order 12898 principally through its compliance with the provisions of NEPA

and other federal laws and regulations.

WS activities are evaluated for their impact on the human environment and compliance with 

Executive Order 12898 to ensure Environmental Justice. WS personnel use BDM methods as 

selectively and environmentally conscientiously as possible. WS assistance is provided on a request 

basis in cooperation with State and local governments and without discrimination against people 

who are of low income or in minority populations. The nature of WS’s BDM activities are such that 

they do not have much, if any, potential to result in disproportionate environmental effects on 

minority or low-income populations. Therefore, no such adverse or disproportionate 

environmental impacts to such persons or populations are expected.

Executive Order 13045 - Protection of Children from Environmental Health and Safety Risks. Children 

may suffer disproportionately from environmental health and safety risks, including their 

developmental physical and mental status, for many reasons. Because WS makes it a high priority 

to identify and assess environmental health and safety risks, WS has considered the impacts that 

alternatives analyzed in this EA might have on children. All WS BDM is conducted using only legally 

available and approved damage management methods where it is highly unlikely that children 

would be adversely affected at all, let alone in any disproportionate way. Based on the Risk 

Assessment (USDA 1997, Appendix P) concluded that when WS program methods are used 

following normally accepted safety practices and WS standard operating procedures, such use has 

negligible impacts on the environment or on human health and safety, which includes the health 

and safety of children.

Executive Order 13112 - Invasive Species. Authorized by former President Clinton, Executive Order 

(EO) 13112 establishes guidance to federal agencies to prevent the introduction of invasive species 

and provide for their control and to minimize the economic, ecological, and human health impacts 

that invasive species cause. The EO, in part, states that each federal agency whose actions may 

affect the status of invasive species shall, to the extent practicable and permitted by law: 1) reduce 

invasion of exotic species and the associated damages, 2) monitor invasive species populations and 

provide for restoration of native species and habitats, 3) conduct research on invasive species and 

develop technologies to prevent introduction, and 4) provide for environmentally sound control 

and promote public education on invasive species. 
Bird Damage Management in Washington - 91

Appendix B

The EO also established an Invasive Species Council whose members include the Secretary of State, 

the Secretary of the Treasury, the Secretary of Defense, the Secretary of the Interior, the Secretary 

of Agriculture, the Secretary of Commerce, the Secretary of Transportation, and the Administrator 

of the U.S. Environmental Protection Agency. The Council shall be Co-Chaired by the Secretary of 

the Interior, the Secretary of Agriculture, and the Secretary of Commerce. The Council oversees: 1) 

the implementation of this order, 2) that federal agency activities concerning invasive species are 

coordinated, complementary, cost-efficient, and effective, 3) the development of recommendations 

for international cooperation in addressing invasive species, 4) the development, in consultation 

with the CEQ, of guiding principles for federal agencies, 5) the development of a coordinated 

network among federal agencies to document, evaluate, and monitor impacts from invasive species 

on the economy, the environment, and human health, 6) the establishment of a coordinated, up-todate information-sharing system and 7) preparation and issuance of a national Invasive Species 

Management Plan. 

Executive Order 13186 and MOU between USFWS and WS. EO 13186 directs federal agencies to 

protect migratory birds and strengthen migratory bird conservation by identifying and 

implementing strategies that promote conservation and minimize the take of migratory birds 

through enhanced collaboration between WS and the USFWS, in coordination with state, tribal, and 

local governments. A national-level MOU between the USFWS and WS has been drafted to facilitate 

the implementation of EO 13186.
Bird Damage Management in Washington - 92

Appendix C

Appendix C Bird Damage Management Methods 

NonLethal Methods

Nonlethal methods can be integrated with lethal methods to increase the efficacy of a management 

program. Birds may acclimate to some nonlethal methods if they are applied for too lengthy a time 

period or incorrectly. On rare occasions, a bird may die from some nonlethal methods listed here. 

Many factors, including weight, stomach contents, or physiology may make individual birds more or 

less susceptible to certain nonlethal management methods. Therefore, conditions unknown to WS 

or beyond the control of WS may be responsible for some mortality during implementation of 

nonlethal damage management techniques. 

Habitat Modification is the practice of altering the habitat in an area to make it less attractive to

wildlife in general or it can target a specific species of wildlife. Wildlife presence is directly related 

to the availability and quality of habitat, so habitat can be managed to reduce or eliminate use of an 

area by some wildlife. Habitat management is appropriate when the potential for damage can be 

reduced without increasing a resource owner’s costs beyond an acceptable level or diminishing 

their ability to manage resources. When wildlife is damaging property, removing or altering the 

source of the attraction is the ultimate goal, but may take time to achieve. Seasonal changes may 

warrant variations in habitat modification plans to be effective. 

Translocation of damaging birds to other areas following live capture generally is not costeffective, as those species causing damage are usually common and numerous throughout WA. 

Translocation of damaging species may cause similar problems at a new location, but often involves 

stress to the translocated animal which may result in poor survival rates. Translocated individuals 

may also leave the area they are released and return to former sites. 

However, there may be situations where bird translocation is the preferred method. That decision 

may be based on available funding, species involved, personnel availability and probability of 

success. Translocation of damaging birds might be a viable solution and acceptable to the public 

when the birds are considered to have high value, such as T&E species. In these cases, WS consults 

with the USFWS and WDFW to coordinate capture, transportation, and selection of suitable 

relocation sites.

Nest destruction is the removal of nesting materials during the construction phase of the nesting 

cycle. Permits are not required to remove the nest of most birds if eggs or chicks are not present in 

the nest. Nest destruction is usually feasible only when dealing with a limited number of birds or 

nest sites. This method is used to discourage birds from constructing nests in areas, which may 

create nuisances or safety concerns for home and business owners. Nest destruction poses no 

imminent danger to pets or the public.

Exclusion devices, such as overhead wire grids, conventional netting and fencing can be effective 

but are often cost-prohibitive, particularly because of the mobility of birds. Exclusion that is 

adequate to stop bird movements can also restrict movements of livestock, people, and other 

wildlife (Fuller-Perrine and Tobin 1993). Some birds may be excluded from ledges, hand railings, 

ponds or other areas using overhead wires/lines (Fairaizl 1992, Lowney 1993). Wire/lines should 

be made visible to the birds by hanging streamers or other objects at intervals along the wires. The 

objective is to discourage bird loafing or feeding activities and not cause injury or death. The 

application of wire arrays and designs at dams are continually adapted and updated to meet 

changing needs based on dam structure, spill patterns, bird foraging activity, etc. 
Bird Damage Management in Washington - 93

Appendix C

Overhead wire networks generally require little maintenance other than ensuring proper wire 

tension and replacing broken wires, though the expense of maintenance may be burdensome. 

Overhead wires have been demonstrated to be most effective on sites less than 2 acres, but may be 

considered unsightly or aesthetically unappealing to some people. In addition, wire grids can 

render a pond unusable for boating, swimming, fishing, and other recreational activities. 

Installation costs are about $1,000 per surface acre for materials. Heavy plastic strips hung 

vertically in open doorways have been successful in some situations for excluding birds (Johnson 

and Glahn 1994). 

Porcupine wire (or similar materials) can be placed on ledges to prevent birds from perching or 

nesting on the ledges. This material can be expensive and debris often collects in the projections 

making it ineffective and unsightly.

Visual scaring techniques, such as Mylar tape, (highly reflective surface produces flashes of light 

that startles birds), eye-spot balloons (the large eyes supposedly give a visual cue that a large 

predator is present), flags, lasers and effigies (scarecrows), are occasionally effective in reducing 

bird damage. Mylar tape has produced mixed results in its effectiveness to frighten birds (Dolbeer 

et al. 1986, Tobin et al. 1988). Birds quickly learn to ignore visual and other scaring devices if the 

birds’ fear of the methods is not reinforced with shooting or other tactics.

Lasers are a relatively new technique used to frighten and disperse birds from their roosts or 

loafing area. Studies have shown that several bird species, such as double-crested cormorants, 

Canada geese, other waterfowl, gulls, vultures, and American crows exhibited avoidance of laser 

beams during field trails (Glahn et al. 2001, Blackwell et al. 2002). The lower power levels, 

directionality, accuracy over distance, and silence of laser devices make them safe and effective 

species-specific alternatives to pyrotechnics, shotguns, and other traditionally available dispersal 

tools (APHIS 2003). Best results are achieved under low-light conditions (i.e., from sunset through 

sunrise) by targeting structures or trees proximal to roosting birds where the beam is projected. In 

field situations, habituation to lasers has not been observed (APHIS 2003). 

The avian eye generally filters most damaging (e.g., short-wavelength) radiation from the sun. In 

tests conducted with double-crested cormorants exposed to a relatively low-power Class-III B laser 

at a distance of 1 meter, no ocular damage was noted (APHIS 2003). However, unlike the eye of 

birds, the human eye, with the exception of the blink reflex, is essentially unprotected from thermal 

damage to retinal tissue associated with concentrated laser radiation. The Class II, batterypowered, 68-mW, 650-nm, diode Avian Dissuader is used by WS in WA. Because of the risk of eye 

damage, safety guidelines and specifications have been developed and are strictly followed by the 

user (OSHA 1991, Glahn and Blackwell 2000).

Auditory frightening devices such as sirens, horns, propane exploders, pyrotechnics, harassment 

shooting, electronic guards, and bioacoustics use sounds to scare birds. Harassment of avian 

predators is accomplished from the shoreline, dam structures, and boats to provide thorough 

coverage. If harassment is not effective, shooting could be used to reinforce nonlethal methods; 

shooting is not used to manage or reduce populations. Nonlethal harassment comprised more than 

98% of WS BDM activities at dams. 

Auditory frightening devices are often not practical in suburban, urban, or rural areas if they 

disturb people, livestock, or pets. Birds may quickly habituate to frightening devices if not 

reinforced with other techniques (Bomford and O’Brien 1990). 
Bird Damage Management in Washington - 94

Appendix C

Paintball guns are an effective tool that can be used to disperse and move birds from an area. 

Paintballs are not fired directly at the birds with the intention to hit them, but in the direction of the 

bird. The firing of a paintball gun produces a gunshot-like report that will often frighten birds. In 

addition to an auditory stimulus, there is also a visual and auditory stimulus from the paintball 

hitting and breaking near the bird. The combination of stimuli increases the efficacy of a 

frightening device.

Other harassment methods include the incorporation of a human physical presence or presence 

of a vehicle. Physical harassment in the form of human voice, waving arms, and clapping of hands 

will often work in many situations when other frightening devices are not applicable. In addition, 

vehicle harassment is also often effective in scaring birds from an area. Vehicle harassment 

involves simply driving towards or near a bird causing it to leave the area.

Hand-capture is an effective way to capture juvenile birds or birds that are unable to fly due to 

injury or molting of flight feathers.

Drive nets are used to catch molting (flightless) waterfowl. Long netting forms a funnel to a 

holding pen. Birds will often flock together on land or water and can be carefully herded into the 

holding pen.

Clover, funnel, cage, and decoy traps are enclosure traps made of netting, hardware cloth, or 

other light fencing material and come in many different sizes and designs, depending on the species 

of birds being captured. The entrances of the traps also varies greatly from swinging-door, one-way 

door, or funnel entrance. Traps are baited with grain or other food material to attract target birds. 

Decoy traps maintain live birds in the trap with sufficient food, water, and shelter to assure their 

survival. Feeding behavior and calls of the decoy birds attract other birds, which enter and become 

trapped themselves. WS’ standard procedure when conducting trapping operations is to ensure 

that an adequate supply of food and water is in the trap to sustain captured birds for several days. 

Active traps are checked daily, every other day, or as appropriate, to replenish bait and water and 

to remove captured birds. Cage/live traps, as applied and used by WS, pose no danger to pets or 

the public and if a pet is accidentally captured in such traps, it can be released unharmed.

Nest box traps are used to capture local breeding and post-breeding starlings and other targeted 

cavity nesting birds (DeHaven and Guarino 1969, Knittle and Guarino 1976).

Remote activated nets can be used to capture ground-nesting birds or birds at baits. The nets may 

have frames of various sizes and shapes or may be frameless, depending on the number of 

individuals and species targeted. The nets are fired by a remote controlled release trigger. 

Triggering the device may either release a frame to close over an area or a net may be propelled 

over a target flock. 

Mist nets are more commonly used for capturing small birds such as passerines or shorebirds, but 

can be used to capture larger birds such as waterfowl. The mist net is a fine black silk or nylon net, 

usually 3 to 10 feet wide and 25 to 35 feet long. Net mesh size determines which birds can be 

caught and overlapping “pockets” in the net cause birds to entangle themselves when they fly into 

the net. Mist nets can be use over land or water. Mist nets are monitored to ensure non-targets 

caught are released quickly and reported appropriately. 
Bird Damage Management in Washington - 95

Appendix C

Cannon nets/rocket nets are normally used for birds such as feral pigeons, gulls, and waterfowl 

and use mortar projectiles to propel a net over birds, which have been baited to a particular site. 

This type of net is especially effective for waterfowl that are flightless due to molting and other 

birds which are typically shy of other capture devices. 

Net guns are effective for capturing individual birds in situations where the use of other capture 

devices is not feasible. A net gun is a heavily modified firearm that uses a blank cartridge to propel 

a net over a target. Nets with different sizes of mesh are available to capture birds of different sizes. 

Weights attached to the corners of the net are placed in four barrels on the gun, while the net is 

carefully placed in a container between the barrels. When fired, gasses from the cartridge drive the

weights out of the barrels and carry the net over the target.

Pole traps are generally set for raptors which perch on poles while hunting for food. Hawks and 

owls can be safely trapped using a small padded-jaw leg-hold trap, snare, or tangle snares set on the 

top of poles. Poles that are 5 to 10 feet high are erected where they can be easily seen, and a trap is 

placed on top of the pole. A wire is run through the trap ring and secured to the base of the pole so 

that trapped birds may slide to the ground where they can rest. Pole traps are monitored regularly 

to quickly remove captured birds.

Bal-chatri traps are small traps used for capturing birds of prey such as hawks and falcons. Live 

bait (e.g., pigeon, starling, a rodent) is used to lure raptors into landing on the trap. The trap is 

made of chicken wire or other wire mesh material and formed into a Quonset hut-shaped cage 

which holds the live bait and is anchored securely to the ground. The outside top and sides are 

covered with many nooses consisting of strong monofilament line or stiff nylon string that entangle 

the raptor’s feet and hold the bird.

Swedish goshawk traps are a type of large cage-trap. Like the Bal-chatri, they use live bait (e.g., 

pigeons, starlings, rodents) to lure a raptor into the trap. The live bait is secured in an additional 

cage inside the trap so the raptor cannot harm the animals used as bait. While attempting to get the 

bait, the raptor releases a trigger that closes the doors of the trap, securing the bird inside the large 

cage.

Leghold/Foothold traps (padded jaw) are a common and effective way to catch animals. The 

trap consists of 2 steel jaws, at least one spring, a pan, and dog (trigger), and come in numerous 

sizes to catch different sizes of animals. When the animal steps on the pan, the jaws are released 

and the spring(s) close the jaws around the foot, securely holding the animal. The jaws of the trap 

may be laminated, offset, or padded to reduce pressure on the animal’s leg/foot.

Methyl Anthranilate is a food flavoring (artificial grape flavoring) that is approved by the Food 

and Drug Administration as an additive to both human and livestock feeds (Timm 1994). It is a 

naturally occurring chemical and is the characteristic odor/flavor of Concord grapes. Methyl 

anthranilate is a taste repellent to birds, causing them to avoid using or feeding in areas where it 

has been applied. Methyl anthranilate is not fundamentally toxic to mammals or birds and at room 

temperature it is an oily yellowish liquid. 

Anthraquinone is registered as a repellent to protect turf from goose damage. Research continues 

and application may become available in the future. Like methyl anthranilate, anthraquinone has 

low toxicity to birds and mammals. Avian species consuming anthraquinone for the first time 

typically exhibit no immediate aversion but are subsequently repelled due to a suspected postingestional response.
Bird Damage Management in Washington - 96

Appendix C

Alpha-chloralose is a central nervous system depressant used as an immobilizing agent to capture 

and remove nuisance water fowl and other birds. It is typically delivered as a well contained bait in 

small quantities with minimal hazards to pets, and humans; single bread or corn baits fed directly 

to the target birds. WA personnel are present at the site of the application during baiting to retrieve 

the immobilized birds. Unconsumed baits are removed from the site following each treatment. 

Lethal Methods

Egg removal/Egg Addling/Oiling/Destruction may take place when nest destruction is used to 

discourage birds from nesting in areas that require protection and is a method of suppressing 

reproduction of local nuisance bird populations by destroying eggs and embryos prior to hatching. 

Eggs that are collected during nest/egg removal activities may be donated to charitable 

organizations or disposed of in a landfill. The removal of nests and eggs often discourages birds 

from nesting in an area, causing them to abandon the site. Egg addling is conducted by vigorously 

shaking an egg causing detachment of the embryo from the egg sac. Egg destruction can also be 

accomplished in several other ways, but the most commonly used methods are manually gathering 

eggs, or by oiling or spraying the eggs with a liquid which covers the entire egg and prevents the 

embryo from obtaining oxygen.

Shooting is a very selective method used to remove birds and reinforce nonlethal methods. 

Shooting is more effective as a dispersal technique than as a way to reduce bird densities when a 

large number of birds are present. Shooting with shotguns, air rifles, and rifles may be used to 

reduce bird damage problems when lethal methods are determined to be appropriate. All 

employees who use firearms receive firearms safety and handling training in compliance with WS 

Directives 2.615 and WS Firearm Safety Training Manual. 

To ensure safe use and awareness, WS employees who use firearms to conduct official duties are 

required to attend approved firearms safety training and receive refresher course every 2 years 

afterwards (WS Directive 2.615). WS employees who carry firearms as a condition of employment 

are required to sign a form certifying that they meet the criteria as stated in the Lautenberg 

Amendment, which prohibits firearm possession by anyone who has been convicted of a 

misdemeanor crime of domestic violence.

Hunting and Depredation Permits. WS will sometimes recommend that resource owners 

consider legal hunting as an option for reducing damage caused by species of game birds. Although 

legal hunting is impractical and/or prohibited in many urban/suburban areas, it can be used to 

reduce the use of a resource by local populations of game birds in the appropriate areas. Legal 

hunting also reinforces harassment programs (Kadlec 1968). WS may recommend that resource 

owners receive DPs from the USFWS to legally take bird species that are protected under the MBTA. 

In these situations, WS will investigate the complaint and provide this information to the USFWS 

either recommending or advising against the permit application by submitting a Form 37.

Snap traps can be effective in removing offending birds. The trap is affixed to the building with the 

trigger pointed downward in the vicinity of the damage. The trap is baited with nuts (walnuts, 

almonds, or pecans) or suet. If multiple areas are being damaged, several traps can be used.

Snares are a simple and effective method to capture animals. Snares made of cable or other line 

can be used to catch target animals. A snare can be place in a tunnel or other small opening used by 

an offending animal (e.g., pigeon). When an animal walks through the loop in the snare, a lock 

slides down the cable and constricts around the animal, holding it in place. A stop can be placed on 

the snare to stop the constriction of the snare and to avoid euthanizing the animal if desired.
Bird Damage Management in Washington - 97

Appendix C

Avitrol® is rarely used by WS (zero to five applications annually) as a management tool for 

problem birds. Avitrol® treated bait is placed in areas where the targeted birds are feeding. Birds 

that consume treated baits normally die (Johnson and Glahn 1994). Birds display abnormal flying 

behavior after ingesting treated baits and emit distress vocalization (pigeons do not). Avitrol® is a 

restricted use pesticide that can only be sold to certified applicators and is available in several bait 

formulations where only a small portion of the individual grains carry the chemical. 

Avitrol® is not selective for targeted birds and exposure to non-target species is possible. It is 

highly toxic to birds and mammals, though blackbirds and corvids may be slightly more sensitive to 

the chemical than other species. In addition, chronic toxicity has not been demonstrated (Schafer 

1991). Laboratory studies with predator and scavenger species have shown minimal potential for 

secondary poisoning. However, in a field study, magpies and crows may have been affected 

secondarily (Schafer 1991). American kestrels (Falco sparverius) that fed on blackbirds for 7 to 45 

days which had died from a lethal dose of Avitrol® were not adversely affected (Schafer 1991). 

Therefore, no probable secondary risk is expected with use of this compound. 

Avitrol® is water soluble, but laboratory studies demonstrated that Avitrol® is strongly absorbed 

onto soil colloids and has moderately low mobility. Biodegradation is expected to be slow in soil

and water, with a half-life ranging from 3 to 22 months. Avitrol® is non-accumulative in tissues and 

is rapidly metabolized by many species (Schafer 1991). 

DRC-1339 is the principal chemical method that would be used for starling and pigeon damage 

management under the proposed action. For more than 30 years, DRC-1339 has proven to be an 

effective method of starling, blackbird, and pigeon control at feedlots, dairies, airports, and in urban 

areas (West et al. 1967, Besser et al. 1967, Decino et al. 1966). Studies documented the 

effectiveness of DRC-1339 in resolving starling problems at feedlots (West and Besser 1976., Glahn 

1982, Glahn et al. 1987) and Blanton et al. (1992) reports that DRC-1339 appears to be a very 

effective, selective, and safe means of urban pigeon population reduction. 

DRC-1339 is a slow acting avicide that is registered with the EPA for reducing damage from several 

species of birds, including blackbirds, starlings, pigeons, crows, ravens, magpies, and gulls. DRC1339 was developed as an avicide because of its differential toxicity to mammals. DRC-1339 is 

highly toxic to sensitive species but only slightly toxic to non-sensitive birds, predatory birds, and 

mammals. For example, starlings, a highly sensitive species, require a dose of only 0.3mg/bird to 

cause death (Royall et al. 1967). Most bird species that are responsible for damage, including 

starlings, blackbirds, pigeons, crows, magpies, and ravens are highly sensitive to DRC-1339. Many 

other species such as raptors, sparrows, and eagles are classified as non-sensitive. Numerous 

studies show that DRC-1339 poses minimal risk of primary poisoning to non-target and T&E 

species (USDA 1995). Secondary poisoning has not been observed with DRC-1339 treated baits. 

During research studies, carcasses of birds which died from DRC-1339 were fed to raptors and 

scavenger mammals for 30 to 200 days with no symptoms of secondary poisoning observed 

(Cunningham et al. 1981). This can be attributed to relatively low toxicity to species that might 

scavenge on blackbirds and starlings killed by DRC-1339 and its tendency to be almost completely 

metabolized in the target birds which leaves little residue to be ingested by scavengers. Secondary 

hazards of DRC-1339 are almost non-existent. DRC-1339 acts in a humane manner producing a 

quiet and apparently painless death. 

DRC-1339 is unstable in the environment and degrades rapidly when exposed to sunlight, heat, or 

ultra violet radiation. DRC-1339 is highly soluble in water but does not hydrolyze and degradation 
Bird Damage Management in Washington - 98

Appendix C

occurs rapidly in water. DRC-1339 tightly binds to soils and has low mobility. The half-life is about 

25 hours, which means it is nearly 100% broken down within a week, and identified metabolites 

(i.e., degradation chemicals) have low toxicity. Aquatic and invertebrate toxicity is low (USDA 

1995). Appendix P of USDA (1995) contains a thorough risk assessment of DRC-1339 and the 

reader is referred to that source for a more complete discussion. That assessment concluded that 

no adverse effects are expected from the use of DRC-1339. 

Sodium Lauryl Sulfate (SLS) is a wetting agent used to disperse and lethally control starling, 

blackbirds, and cowbirds where they roost (USDA 2008). SLS is a surfactant commonly used in 

soap products. When applied, SLS allows water to penetrate and saturate feathers so, in 

conjunction with low temperatures (<41° F) and sufficient water, birds die of hypothermia. In 

studies, birds died as soon as 30 minutes after exposure to SLS. 

SLS was exempted from FIFRA regulations by the EPA, but states retain the right to accept the EPA’s 

regulatory exemption or require further State registration. Application methods should be in 

compliance with FIFRA 25(b) exemption requirements. 

Euthanasia Methods

Cervical dislocation may be used to euthanize birds which are captured in live traps. The AVMA 

approves this technique as a humane method of euthanasia and states that cervical dislocation, 

when properly executed, is a humane technique for euthanasia of poultry and other small birds 

(AVMA 2007). Cervical dislocation rapidly induces unconsciousness, does not chemically 

contaminate the tissue, and is rapidly accomplished (AVMA 2007).

Carbon dioxide (CO2) is a colorless, odorless gas approved by the AVMA as a euthanasia agent 

(AVMA 2007) and used by WS in cases where live caught animals need to be euthanized. . The 

advantages of using CO2 are: 1) its well established rapid depressant, analgesic, and anesthetic 

effects, 2) its ready availability (e.g., can be purchased in compressed gas cylinders), 3) its broad 

safety margin (e.g., poses minimal hazard to personnel when used with properly designed 

equipment), and 4) its negligible bioaccumulation potential. Inhalation of CO2 causes little distress 

to the birds, suppresses nervous activity, and induces death within 5 minutes. In addition, 

inhalation of CO2 at a concentration of 7.5% increases the pain threshold, and higher concentrations 

of CO2 have a rapid anesthetic effect (AVMA 2007).
Bird Damage Management in Washington - 99

Appendix C

Literature Cited 

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Blackwell, B.F., G.E. Bernhardt, and R.A. Dolbeer. 2002. Lasers as non-lethal avian repellents. J.

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Besser, J.F., W.C. Royal, and J.W. DeGrazio. 1967. Baiting starlings with DRC-1339 at a cattle feedlot. 

J. Wild. Manage. 3: 48-51.

Blanton, E.M., B.U. Constantin, and G.L. Williams. 1992. Efficacy and methodology of urban pigeon 

control with DRC-1339. Proc. East. Wild. Damage Cont. Cong. 5: 58-62.

Bomford, M., and R.H. O’Brien. 1990. Sonic deterrent in animal damage control: a review of device 

tests and effectiveness. Wildl. Soc. Bull.. 18: 411-422.

Cunningham, D. J., E. W. Schafer, and L. K. McConnell. 1981. DRC-1339 and DRC-2698 residues in 

starlings: preliminary evaluation of their effects on secondary hazard potential. Proc. Bird. 

Cont. Sem. 8: 31-37.

DeCino, T.J., D.J. Cunningham, and E.W. Schafer. 1966. Toxicity of DRC-1339 to starlings. J. Wild. 

Manage. 30: 249-253. 

DeHaven, R.W. and J.L. Guarino. 1969. A nest box trap for starlings. Bird Banding 40: 49–50. 

Dolbeer, R.A., P.P. Woronecki, and R.L. Bruggers. 1986. Reflecting tapes repel blackbirds from 

millet, sunflowers, and sweet corn. Wildl. Soc. Bull. 14: 418–425.

Fairaizl, S.D. 1992. An integrated approach to the management of urban Canada geese 

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Glahn, J.F., S.K. Timbrook, and D.J. Twedt. 1987. Temporal use patterns of wintering starlings at a 

southeaster livestock farm: implications for damage control. Proc. East. Wildl. Damage Cont. 

Conf. 3: 194-203.

Glahn, J.F., and B.F. Blackwell. 2000. Safety guidelines for using the Desman laser and Dissuader 

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Glahn, J.F., G. Ellis, P. Fioranelli, and B. Dorr. 2001. Evaluation of moderate- and low-power lasers 

for dispersing double-crested cormorants from their night roosts. Proc. East. Wildl. Damage 

Manage. Conf. 9: 34–45.
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Appendix C

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Timm, and G. E. Larson, editors. Prevention and control of wildlife damage. University of 

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Knittle, C.E. and J.L. Guarino. 1976. Reducing a local population of starlings with nest-box traps. 

Proc. Bird Control Sem. 7: 65–66.

Leopold, A. 1933. Game Management. Charles Scribner’s Sons, New York, NY, USA. 

Lowney, M.S. 1993. Excluding non-migratory Canada geese with overhead wire grids. Proc. East.

Wildl. Damage Manage. Conf. 6: 85–88.

OSHA (Occupational Safety and Health Administration). 1991. Guidelines for laser safety and 

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Royall, W.C., T.J. DeCino, and J.F. Besser. 1967. Reduction of a starling population at a turkey farm. 

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University of Nebraska Cooperative Extension, Lincoln, USA.

Tobin, M.E, P.P. Woronecki, R.A. Dolbeer, and R.L. Bruggers. 1988. Reflecting tape fails to protect 

ripening blueberries from bird damage. Wildl. Soc. Bull. 16: 300–303.

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River Road, Unit 87, Riverdale, MD 20737. 

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West, R.R., and J.F. Besser. 1976. Selection of toxic poultry pellets from cattle rations by starlings. 

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Vert. Pest Con. 3: 89-93.