## ENVIRONMENTAL ASSESSMENT

Bird Damage Management in Washington

Prepared by:

UNITED STATES DEPARTMENT OF AGRICULTURE Animal and Plant Health Inspection Service

Wildlife Services

September 2011TABLE OF CONTENTS

Chapter 1 PURPOSE AND NEED FOR ACTION

................................ ................................ .... 8

1.1 Introduction

................................ ................................ ................................ ................................ .... 8

1.1.1 Wildli fe 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 Ag riculture

................................ ................................ ................................ ................................ ... 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 a nd 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

................................ ................................ ................................ ................................ ... 222.1.2 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 Introduc ed and Invasive Species

................................ ................................ ........................... 35

2.3 T&E Species in Washington

................................ ................................ ................................ .. 35

Chapter 3 ALTERNATIVES AND METHODS

................................ ................................ ..... 38

3.1 Introduction

................................ ................................ ................................ ................................ . 38

3.2 Descript ion of Alternatives Analyzed in Detail

................................ ............................... 38

3.2.1 Alternative 1

– Continue the Current WA WS Bird Damage Management Program,

Nonleth al 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

................................ ................................ ....... 413.4.3.2 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

................................ .. 694.4.3.2 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

................................ ............. 7 1

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 Su mmary

................................ ................................ ................................ ................................ ...... 72

Chapter 5 L IST of P REPARERS , R EVIEWERS , and P ERSONS C ONSULTED

....... 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

................................ ............................ 92Acronyms 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 EndangeredUSACE 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 TransportationBird Damage Management in Washington

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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, s ome species not only adjust to human presence, but thrive well beyond the carrying capacity of what natural habitat w ould 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 Imp act Statement (EIS) (USDA 1997 1 ) 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 provid ing 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

W ildlife acceptance capacity, also known as the cultural carrying capacity, is the limit of human tolerance for wildlife or the maximum number of a given sp ecies 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 environmen t 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 affec ted 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

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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 offend ing 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 punish ing 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 th reats to resources. WS implements IWDM in accordance with the WS

Decision Model 2 (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, spec ies, 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, illus trated 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, environmen tal, 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 re

evaluated 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 me ntal 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 t echnical 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 zoonot ic 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 s tate or federal government

.

Before WS conducts wildlife da mage 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 2.210 3 ). WS works on a cost

- share basi s 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 Me moranda 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

r esource. TA includes recommendations, guidance, and instruction on how to use BDM methods that can be safely and effectively used by cooperators. WS i s 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 requestin g operational damage management assistance are also encouraged to use nonlethal management strategies 4 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 b e a prerequisite to obtaining state or federal wildlife permits.Bird Damage Management in Washington

- 1 1

A range of legal operational damage m anagement 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 publi c and private lands where an Agreement for Control, or other appropriate document, is signed . All B DM would comply with applicable federal, state, and local laws, permitting processes and current MOUs, Memorandums of Agreement s (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 Departm ent 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 i dentified

.

1.3 Purpose of the Environmental Assessment

W ashington (WA) WS developed multiple En vironmental 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 canade nsis ) (November 1999), non

- migratory, feral, Federal Depredation O rder birds (November 2000), migratory birds (October 2001), and piscivorous birds ( June 2003) . Each EA w as written as the need for assistance with bird damage was requested from private/pub lic 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 e valuate its impacts, actions, c umulative 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 regulation s 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 methods 5 . Most wildlife damage situations require professional expertise, an organized dama ge 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 s trategies in the context of their availability (legal and administrative) and suitability based on biological and social

considerations 6 . Following this evaluation, the method(s) deemed to be practical are implemented into a management strategy for the si tuation. WS’ BDM is coordinated with regulatory and wildlife management agencies and serves to provide effective resolution of bird damage problems

. T he 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 i mplemented. WS employees provide TA on a variety of methods that resource owners/managers may use, including localized habitat modification and exclusion 7 . 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 methods 8 implemented under the Proposed Action c ould include: harassment, exclusionary devices, auditory and visual deterrents, repellents , recommendations for habitat modification, and live trap ping and translocation. Lethal methods implemented under the Proposed Action

c ould 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

an d 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, th e 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 wit h annually issued USFWS and/or WDFW permits, federa l 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 FY0 6 through FY 10

, 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 t o requests for assistance to
reduce bird damage or potential damage in WA

.
The sections below provide a descr iption of resources damaged by birds in W A

. 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 cro ps from wildlife damage. W A has approximately 39,400 agricultural production farms and 14,800,000 acres in agriculture production, and the total value of all agriculture in W A is approximately $7.7 billion ( National Agriculture Statistics Service (NA SS) 2 009 )

. Agriculture

, as a whole

, (including production, processing, marketing, etc

. ) accounts for approximately 13% of the gross state product (NASS 2010 ) . F ield crops, fruit, berry, and nut crops, as well as livestock production are all susceptible to dam age from birds. Bird damage reported to WA WS for the FY0 6 through FY10 period totaled nearly $ 1. 5

million and encompassed several types of damage (MIS 2011 ). These damage s pose a significant economic threat to individual agricultural producers and may a ffect
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.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 fec es

. 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 occurrin g 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, ventila tion 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 ar eas 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 feces

contaminated dust in ventilation systems.

1.5.2.2 Human Safety Concerns

WA WS responds to request s for assistance regarding bird hazards at airports. The need to respond to requests for assistance from airports is based on the poten tial for loss of human life and expensive damage to aircraft

. From FY06 through FY010

, t he 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 n aval ai rcraft in W A

.

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 damage s to buildings, structures, and other property are not only expensive, but can lead to heal th and safety concerns. Bird feces and nesting material can damage vehicles, homes, buildings, aircraft, water craft, equipment, bridges, industrial facilities, and other property. Birds

nest ing in utility structu res may caus e power outages by short ing

- o ut transformers

and substations ( e.g ., l oss of electricity can threaten human health when medical equipment is affected or people cannot heat their homes o r get running water)

.

1.5.2.4 Protection of Natural Resources

WA WS works with several agencies to protect natural resources and t hreatened

and e ndangered ( T&E ) species . Agencies includ e : the U.S. Army Corps of Engineers ( USACE ) , USFWS, National Marine Fisheries Service ( NMF S)

, Public Utility Districts (PUD’s), WDFW , and others

. Migrating T&E salm on and steelhead smolt become

more susceptible to predation by birds as they pass through dams on theirBird Damage Management in Washington

- 15

migrat ion to the ocean . D ams locally concentrate their numbers and the currents at

outfalls can c ause them to become temporarily disorient ed and remain near the surface where they are more vulnerab le 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.

F ish bypasses , “fish friendly” turbines, and many other measures are constructed by hydroelectric facilities to protect and enhance salmon and steelhead survival.

H ydroelectric facilities also work to protect migrating smolt from t he opportunistic feeding activities of predatory birds

. WS assists these facilities and agencies to
reduce this predation. Other damages to natural resources caused by b irds

, especially waterfowl and gulls

, can include damage to watersheds and soil from

over grazing

, 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 i s not always possible to assign a value to natural

re sources

. 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

estimate s that it takes 50 ju venile salmon to return one adu lt, 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 fo r 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

r equested. 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 possib le. 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 c overing 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 attem pts 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 N ative American T ribes 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 agre ement 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 e nsure 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) , U SACE , WDFW , or other publicBird Damage Management in Washington

- 17

land management agency under the appropriate permits and authorizations

. The strategies and metho ds 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 w ould 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 import ant 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, thes e 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 safety 9

, 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 curre nt WS program is subject to legal/administrative authorities ( e.g ., Ac t 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 evaluati ng 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: trai ning 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 pr ograms; 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

re sponsible 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 c ooperative 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 m igrating 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 t o protect and enhance Oregon's fish and wildlife and their habitats for use and enjoyment by present and fu ture generations.

Washington Department of Fish and Wildlife

. WDFW has the commission to “preserve, protect, perpetuate, and man a ge 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 follow s 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.

Endan gered 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 thatBird 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 21.4 1). European s tarlings ( 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 ) , Br ewer’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 com mit 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 P ermits 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 Augus t 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

- 6 68d, 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 activit y 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 Heal th 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 pract ical, 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 con cerns 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 equ al protection under the law for all environmental statutes and regulations without discrimination based on race, ethnicity, or socioecon omic status. The nature of WS’ BDM activities is such that they do not have much, if any, potential to result in dispro portionate 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 Hea lth 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 w hen 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 t he 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 mini mize 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) prov ide 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

identi fying 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 Resi dent 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 damag e reductions

. On August 10, 2006, WS issued a R OD 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 USF W S a nd WDFW to reduce r esident Canada g oo se 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 po rtions of the E A 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) T he 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 AFFE CTED 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. W A

State contains 66,582 square miles of land and 4,721 square miles of wa ter. 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, m ore 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). W A ’s top agricultural products include field crops, fruits and nuts, and livestock and their products (NASS 2009).

Producers in WA fac e 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 responsi ble for pulling seedling crops . F rom FY06 throughF Y10 , 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 g eese, starlings, cowbirds, English sparrows, and feral pigeons caused more than $ 300 ,000 in damages to gra ins and pasture crops in WA from FY06 through FY10 (MIS 2011 )

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

. Many bird species find livestock production facilities attractive food sources because of the protein additi ves 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

feedlot s in WA (MIS 2011 ). Large flocks of birds also carry species of mites that may be introduced into poultry houses (Kern 1997). Black

- billed m agpies ( 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

W A ’s aquaculture industry produces a large array of product s 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

loaf ing 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

enha ncement) 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 h erod ias ) 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 W A

, just those reported to WS . Damages are only reported t o 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 assistan ce to 39 airports in W A 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 vic inity 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 t hreat 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 bir ds 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 pigeon s . 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 a nd 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, vu ltures ( 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 pass engers 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 th rough 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 20 09 ). Consequently, the num ber of birdstrikes in WA is most likely much higher than records indicate.

2.1.2.2 Human Health 11

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

in fectious 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 airpor ts 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 fai ling 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 W A include salmonellosis, chlamydiosis, histoplasmosis, Newcastle disease,

W est Nile virus, and avian influenza. Salmonellosis, chlamydiosis, West Nile virus, and highly pathogenic avian influenza are reportable diseases.

Accumulations of bird fec es 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 v irus 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 amo unt 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

spec ific 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 million s of dollars in damage each year to homes, boats and marinas, aircraft, parks, equipment, machinery, industrial facilities, roads and bridges, park s, 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.Bird Damage Management in Washington

- 26

The removal of bird fe ces 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 e rosion 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 La ndfill 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 landf ills 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 neighbo rs over odor, noise, vibration, and bird problems (Seattle Post

- Intelligencer 200 0 ). Birds at landfills also defecate on buildings and equipment, risking the health of landfill employees through contact with fecal matter and contaminants from the

la ndfill carried by the birds. Landfills and transfer stations in WA are required to conduct activities to reduce the potential for bird damage (W ashington

Administrative Code [ W AC ] 173

- 351

- 200). In some cases these facilities request

assistance from WS.

WS cu rrently assists landfills in W A 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 minim ize 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 th e 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 federa l resource management agencies, including WDFW, ODFW, USFWS,Bird Damage Management in Washington

- 27

NMFS, USACE, and PUD s to develop and implement an adaptive and integrated program to reduce avian predation at hydroelectric facilities. Hydroelectric development changed the Columbia River basi n beginning in 1933 from mostly free

flowing 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 development s 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 condition s 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 i s 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 t hrough 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, a vian 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 N MFS.
Hundreds of m illions of dollars have been spent to increase salmon survival through

the 13 hydroelectric facilities along the Columbia and Snake Rivers in Washington ( e.g ., a pprox imately 1⁄3 of the Grant County PUD’s entire annual budget goes to fisheries improvements ) . These expenditures include the installation new fish

friendly turbines in two dams, research for the design and the installation of fish bypass structures, the insta llation 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 approxi mately $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 mana gement to reinforceBird 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 stru cture, 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 preve nting predation, shooting is used to reinforce nonlethal

methods ; s hooting 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 speci fic 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 conser vation 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 wh ile 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 contribu ted more than $1 billion to Washington’s economy in 2000.
These hatcheries are an ess ential tool in the conservation of native, listed salmonids.

Hatchery

- raised juvenile smolt are used to strengthen ESA

- listed species r ecovery efforts and supplement t ribal, 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 re main at aquaculture facilities year round. P roximity 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 pred ators 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 s molt 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 Wi re 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 values 12 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 pred ation 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 (200 4 ) 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

T ribal Treaty obligations, and directly assist in the recovery of ESA

- listed species (WDFW 2002, letter to WS). The application of monetary valu ations 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 lis tings 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 I n 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 spec ies. 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 $6Bird 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 D epredation O rder

. 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 cond uct BDM
under d epredation o rders 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 s pecies encountered in damage situations in WA inc lude Brewer’s, red

- winged, and yellow

- headed blackbirds, brown

- headed cowbird s, American and n orthwestern 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 c onflicts with waterfowl are often addressed through hunting opportunit ies, urban conflict generally requires alternative approaches. Waterfowl are involved in damage situations in all of the resource categories analyzed in this

document. W aterfowl are most commonly implicated in damage situations at airports where they pre sent 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 damag e 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 Heal th 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 ev en been suggested as contributing

to increase s 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 propert y 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 dir ect 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 wh en 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’ pop ulations, especially when depredation occurs on T&E species. Locations with naturally occurring fish populations often attract gulls,

and fish hatcheries are fr equently constructed near naturally occurring concentrations of fish (Schaeffer 1992). Gulls c ause 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, s uch feeding strategies may present disease threats to li vestock 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. G ulls 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.

C alifornia 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, V auk

- Hentzelt et al. 1987, Quess y and Messier 1992). Transmission of bacteria from gulls to humans is diffic ult to document; however, Reill y 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 acceleratedBird 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, t erns 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 t erns ( Sterna caspia ) are on e 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

t ern 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

ODF W 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 w estern states in effort to disperse this colony to other areas in

west ern North America (USFWS 2010 online)

.

Additional, smaller Caspian tern colonies exist throughout the Columbia River Ba s in.
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 s molt, can be
substantial 13 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 no t propose to conduct lethal damage management for Caspian t erns.

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 ) . Double

crested cormoran ts 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 Ba sin 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 i n 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 o nline )

. 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 oc curred primarily at marinas, boat docks, shipyards, and bridges in marine environments.

C ommon mergansers ( Mergus merganser americanus ) are piscivorous waterfowl that impac t 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. 200 2 ). 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 ge nerally involved in human

- wildlife conflicts ; however t here 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 h ouse fi n ches are commonly encountered depr edating 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 o r maintenance project can continue. Failure to take action could lead to critical safety projects being un completed and delays costing tens of thousands of dollars.

2.2.7 Shorebirds

Shorebirds in Washington have resident and migrant populations ( Larsen et al. 20 04 ). The estuaries in the northern Puget Sound provide some of the highest counts of

shorebir ds throughout the state, with estimate s exceeding 170,000wintering

shorebirds in WA ( Larsen et al. 200 4 ). Shorebirds are rarely encountered in human

-Bird Damage Management in Washington

- 35

wil dlife 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 bir ds on airfields. Their te ndencies 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 acti vity on airports increases risk to aviation safety, because adults increase hunting and flight activity while building nests and rearing young. R aptor nests on communication towers, bridges, utility poles, and other structures may impede or prevent mainte nance

.

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 i nvasive 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 Pr oposed 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 re consult 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 Washington 14

. 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

bird s 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 o nline) . In 2010 white pelicans were documented nesting in small numbers at two locations on the Columbia River (J. Hoskins

, USFWS,

p ers

. c omm

. 2010)

. Pelicans are routinely seen congregating at outfalls where salmon

smolt are concentrated. Passive Integrated Transponder ( PIT ) tag recoveries from the Badger Island p elican colony show that less than one PIT

- tagged smolt was con sumed per nesting adult. This is a low number compared to other piscivorous birds, such as

cormorants which consumed 16.2

- 16.5 PIT

- tagge d smolt per nesting adult in two colonies (BRN o n l ine). W hile 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 MET HODS

3.1 Introduction

Alternatives were developed for consideration usin g 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 reco gnized, 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 environ mental 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 wo uld 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, t his EA analyzes the effects from existing actions while tryi ng to forecast potential needs for assistance and analyzes the impacts from those potential actions. Substantial c hanges

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. P reference 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 spe cies involved. Operations under this alternative are directed at alleviating damage and not intended to control populations of any native species 15

.

15 In damage situat ions 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 r equest 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 damag e caused by birds. In general terms, B DM 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 harassm ent, and/or lethal removal (Appendix C ). Methods are implemented at the field level according to WS Directive s 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 acti vities 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 implemen ted 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 use d. 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 operatio nal 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

Th e 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 da mage 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 De cision
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 de sired 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 losse s. WS
uses the Decision Model to det ermine 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, t he 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 w hen 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 wild life 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 managem ent 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 dama ge 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 int erested 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, rec ommendations, information, equipment, literature, instr uctions, and materials to assist others in prevent ing or reducing wildlife damage and in understand ing BDM principles and techniques. Explanation of the biology, behavior, and population ecology of th e 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

autho rity or control of the actions taken by others.

3.4.3 Operational Bird Damage Management

Operational BDM is field activit y conducted by WS personnel. It is generally applied when the problem cannot reasonably be resolved by TA or when the prof essional 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 method s a re 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 harass ment and/or removal of birds or nes ting materials from rooftops

near ventil ation intakes before they ha ve 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 reduc e bir d 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 deta il 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 Ma nagement Program (No

Action /Proposed Action )

Alternative 2

– Implement All Nonlethal Methods Before Using Lethal Methods

Alternative 3

- Technical Assistance BDM Program Onl y Alternative 4

- No WS BDM ProgramBird Damage Management in Washington

- 43Bird Damage Management in Washington

- 44

CHAPTER 4 ENVIRONMENTAL CONSEQ UENCES

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 c hapter provi des 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 Chap ter 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

S oils, geology, minerals, flood plains, visual resources, air quality, or prime and unique

farmlands with in 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 Unavoidabl e 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 de pendent 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, numb er, 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

i mplementing 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 WA 16 and WS’ take of native wildlife species is a small proportion and insignificant to the viability and health of the total population.

T here 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 t he state of WA wou ld 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 analy zing 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, Ap pendix 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

i mpossible 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 illne ss 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

p roperty 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 cit ies 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 order s

. Additionally, WA WS preferentially uses non

- toxic shot for theBird 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 fe deral 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

Aestheti cs 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 ow ner 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

environmenta l changes. Conover (2002) describe s 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 anthrop ogenic 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 r ecent 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 humanBird 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 thre sholds 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 (D ecker 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, site

specific effect on people’s opportunities to view some individual birds or flocks. However, bir d 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, a n 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 Effec t of Damage Management Methods on Non

- target and ESA

- listed Species

Non

- lethal Methods

Overall, impacts to non

- target s pecies from the use of nonlethal methods would be similar to the use of nonlethal methods under any of the alternatives. Non

- target

s pecies 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’ i nvolvement in the use of or

recommendation of nonleth al 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 no n

- target s pecies when exposed to or when ingested.Bird Damage Management in Washington

- 49

Lethal Methods

WS c ould 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 alternati ve would include shooting , traps, Sodium Lauryl Sulfate (SLS) and the avicide s DRC

- 1339 and Avitrol

. In addition, birds could also be

euthanized once live

- captured by AVMA approved methods ; l ethal take of live

captured birds would occur pursuant to WS Directive 2.505. Available methods and the application of those methods to resolve bird d amage is further discussed in Appendix C

. Shooting would be used for l ethal reinforcement and a s the last step of this integrated BDM pro gram. 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 ; i n 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 ret urn 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 a nd 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

po ssible 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 bird s , 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 bird s from damage sites. Continually harassing habituated birds (without using lethal reinforcement) frequently s erves 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 hundre ds 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 th is
method. When using pesticides, WS follows all p esticide l abel requirement s 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

- treatmentBird Damage Management in Washington

- 50

observations section of the label. By acclimating target s pecies to a feeding schedule, baiti ng can occur at specific times to ensure bait is quickly consumed by target species, and is unavailable to non

- target s pecies

. 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 preferr ed by non

- target species.

Once sites are baited, they are monitored to further observe for non

- tar get 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 ar e 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 App endix C which are determined to be practical, legal, and effective.

WS initiated consult ation 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 be havioral 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 the m

. WA WS strives to limit take of native species o f birds. For FY06 through FY 10 , 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 admini stered 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 ., Europe an 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 a irpo rts 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 eagle s ) 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 we re lethally removed during BDM actions 17 . 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 qualit atively.

WA WS take is presented as 5

- year average s for activities from FY06 thro ugh FY 10 (Appendix A)

. The analysis considers a level of take that may be necessary to sufficiently reduce damages and meet future requests for assistance. However, t he numbers presented do not necessarily represent planned take. A ll take of migratory bird species is regulated and permitted in advance by the USFWS and a ny future requests for take would be reviewed and analyzed by the USFWS before the

necessary permits are issued 18

. WS responds to requests for assistance and may be asked to provide assistance at any time . T he level of take analyzed in this EA is higher than what is currently occurring to account for possible future requests which could include additio nal 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 air ports 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 an d 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 n eed 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 populations 19 . 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 a irports in emergency situations”

. 18 Species included in d epredation o rders 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 an d 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 vo luntary hunter

- completed surveys and are provided for comparison purposes 20 . 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 e ach 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 )

. USFW S breeding

s urveys of waterfowl breeding ground s 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 200 9 shows wigeon populations are relatively stable in WA since 1968 (Sauer et al.

20 11 ).

From FY0 6 through FY 10

, 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 0.0 04 % of the estimated population, and would not significantly impact the distribution, abundance, or populati on 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 )

. USFW S 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 200 9 shows the gree n

- winged teal po pulation has been stable in WA since about 1978 (Sauer et al. 20 11 ).

From FY06 through FY10

, WS dispersed an average of 343 and lethally removed an average of 1 8 green

- winged teal per year on projects relevant to this EA. Based on the ye arly average, WS took 0.0 8 % 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, abun dance, 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 2 00 9 was 21,527 (WDF W 2009). The BBS population trend data from 1966 to 2007 shows the bufflehead population is stable in WA (Sauer et

al. 20 11)

.
From FY06 through FY10

, WS dispersed an average of 7,785 and lethally removed an average of 11 bufflehead pe r 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

20 06 through 2009 was 5,568 ( WDFW 2009). USFW S breeding surveys of

waterfowl breeding ground s 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 populati on trend data from 1966 to 200 9 shows the gadwall population has steadily increased in WA since about 1978 (Sauer et al. 20 1 1 ).

From FY06 through FY10

, WS dispersed an average of 474 and lethally removed an average of 17 gadwall per year on projects rele vant to this EA. WS could take up to 50 gadwall per year, less than 1 % 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 ). USFW S breeding surveys of waterfowl breeding ground s 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 200 9 shows the mallard population is stable in WA (Sauer et al. 20 11 ).

From FY06 through FY10

, WS destroyed an average of 6 mallard eggs, dispers ed an average of 1, 663 birds, and lethally removed an average of 122 mallar ds per year on projects relevant to this EA

. WS could take up to 30 0 mallards per year, equaling 0.0 8 % of the estimated WA population, and would not significantly impact the distribution, abundance, or population trend of the species.Bird Damage Management in Washington

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Northern Shoveler Population Impacts

The estimated average northern shoveler ( A. clypeata ) wintering population in

WA from 2006 through 2009 was 4,444 ( WDFW 2009)

. USFW S 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 a v erage (USFWS 2009). The BBS population trend data from 1966 to

200 9 shows the shoveler population is relatively stable in WA (Sauer et al. 20 11 ).

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 than 1.3 % of the estimated wintering population (not

all shovelers are taken during the winter) , and would not significantly impact the distribution, abund ance, or population trend of the species.

Rin g

- necked Duck Population Impacts

The estimated average ring

- necked duck ( Athaya collaris ) wintering population in

WA from 2006 through 200 9 was 14,364 (WDFW 2009). USFW S breeding

surveys of waterfowl breeding g rounds do not include ring

- neck ducks in the

P acific F lyway. The BBS population trend data from 1966 to 200 9 shows the ring

necked duck population is increasing in WA (Sauer et al. 20 11 ).

From FY06 through FY10

, WS dispersed an average of 414 and lethally removed an average of 1 1 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 pop ulation trend data from

1966 to 200 9 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.

20 11 ).

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 EA 21

. 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

woul d 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 G oose Population Impacts

The Pacific p opulation of greater white

- fronted geese ( Anser albifrons ) nest s on the Yukon

- Kuskokwim Delta and wint er 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 airport s in western WA in 2008, and it may be necessary t o 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 g oo se per year on projects relevant to this

EA. For analysis purposes, WS could take up to 50 greater white

- fronted geese per year, equaling 0.0 0 9% of the estimated P acific population, and would not significantly impact the distribution, abundance, or population trend of the species.

Tundra Swan Population Impacts

Tundra swans ( Cygnus columbi anus ) 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 W A, 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 weste rn 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

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4.4.1.2.2 Gulls

Gull s 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 gull s to protect human health and safety,
property , natural resources, and agriculture. WS expects requests to reduc e gull damages to continue and will provide assistance

, as requested. The numbers presented in the analysis below do not necessarily represent planned take. A ll take of migratory bird spe cies is regulated and permitted in advance by the

USFWS and a ny 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

N orthwest coas t and hybridize extensively with western gulls ( L

. occidentalis ) (Hayward and Verbeek 200 8 ). For that reason, t hese species along with their hybrids are considered together for this review. The North American population

of g laucous

- 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 co mplete d 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 at tempted 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 Puge t 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 resi ding 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 )

. G laucous

- winged gulls have been

obser ved 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) ofBird Damage Management in Washington

- 57

glaucous

- winged gulls i n other cities and locations (primarily rooftops) around Puget Sound that have not been inventoried in official gull surveys ( MIS 201 1).

The majority of WS’s lethal take of glaucous

- winged gulls / western gulls occurs at

landfills and trash transfer statio ns 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 n ot 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 th e 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 recogniz e 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 kn ow 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 the se new birds do not depart when WS approaches. These individuals/flocks must be conditioned just as descri bed

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 flock s 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 additiona l 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 bird s, 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 one

third of the gulls removed during this time are sub

- adults that are not routinely counted in any of the breeding colony surveys.

G laucous

- 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 sp ecialists 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 counte d during US FWS 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 FY 10 , 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 glaucous

winged /western gull population continues to be healthy in WA, concurrent with

WS’ BDM activities (Fig ure 4. 2 )

.

Based on the historic annual average take

, anticipated projects, and the positive

trend in the Washin g ton 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 glaucous

winged /western gull populations

.

Figure 4. 2 BBS Trend for Glaucous

- winged Gulls in Washington (left) and the Western BBS Region (right) for 1968

- 200 9 (Sauer et al. 20 11 )

. Herring Gull Population Impacts

Herring gulls ( L

. argentatus ) are common in WA and may hybridize with glaucous

winged gulls (Pierotti and Good 1994). WS dispersed an average of 1 0,581 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 re quest ed to remove up to 15 0 herring gulls to protectBird 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 A merica ( BNA ) estimated the tota l 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 RealTimeResear ch 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 disperse d an average of 136,680 and killed an average of 1,0 7 6 California gulls per year. Based on the yearly average, anticipated projects, and the stable to p ositive trend in the population (Sauer et al. 2011), WS could possibly remove up to 2, 5 00 California gu lls 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 g ulls

a re widely distributed across North America, and populations have increased

since the mid

- 1990s in response to increased hu man

- related food sources

.

From FY06 through FY10 , WS dispersed an average of 69,074 and killed an average of 922 ring

- billed gulls a nnually

. 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 3,4 00 ring

- billed gulls per year and not impact the distribution, abundance, or population tr end 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 o nline). The BBS shows that d ouble

- crested cormorant populations in

WA have increased during the last severa l decades (Sauer et al. 2011 ). WA WS harassed an average of 51,652 double

- crested cormorants and killed an av erage 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

y ear and not impact the distribution, abundance, or population trend of the species.

Great Blue Heron Population Impacts

Great blue herons in W A are highly adaptable and largely year round residents (S eattle Audubon 2005 ). Most conflicts with herons occu r 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 an d spring migration periods. WS harassed an average of
3,867 and killed an average of 19 herons per year from FY06 through FY10

. Harassment occurr ed primarily at fish hatcheries and hydroelectric facilities,

while WS take was restricted to airf ields. WA WS could take up to 50 great blue herons per year ( about 0.53 % of the estimate d 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 popul ation 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 depred ation 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 F light estimates that there are 1,700,000 Brewer’s blackbirds in WA (RMBO 200 4 ) and the BBS shows t hat the Brewer’s blackbird population s in WA are stable (Sauer et al. 2011)

. WA WS harasse d an average of 14,577 and kill ed an

average of 1,433 B rewer’s blackbirds per year. WA WS does not anticipate taking

, but could take up to

, 10,000 B rewer’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 200 4 ) . 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 lay s 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 par asitic activities can have a

detrime ntal impact on other native birds ( Seattle Audubon 2005 ). Partners in Flight estimates that the W A 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 FY 10

. 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 200 4 ), and the BBS trend for WA is relatively stable (Sauer et al. 20 11 ). WA WS harassed an average of 31,6 88 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 ( R M BO 2004 ). WA WS dispers ed an average of 1, 105 and lethally removed and average of 81 northwestern crows per year from FY0 6 through FY 1 0. 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 19 66 (Sauer et al. 20 11 ). 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 Pas serine Species

Common Raven Population Impacts

C ommon ravens in W A show an increasing population trend ( Sauer et al. 2011 ). According to Partners in Flight, the breeding population of common ravens in Washington is a pproximately 21,000. WS dispersed an average of 4,021 and killed an average of 25 ravens per year

. WA WS could take up to 25 0 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 estimate s that the WA northern flicker population is approximately 190,000. The BBS trend shows a relatively stable populat ion 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 Po pulation Impacts

House finches are common predators of fruit crops in WA and are often associated with starlings in agricultural depredation situation s

. P artner s in Flight estimates that the WA population of house finch es is approximately 520,000 (RMBO 20 0 4 )

. The BBS shows a n increas ing 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 1,3 00 house finch es per year (0. 25 % of theBird 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 receiv ed increasing complaints from agricultural producers since 2006

. WA WS dispers ed an average of 127 and lethally removed and average of one American robin per year from FY06 through FY10.

The BBS shows a n increas ing population trend in American robin populations (Sauer et al. 201 1)

, and Partners in Flights estimates there are 6,200,000 robins in Washingto n ( R MBO 2004 ) . WS could take up to 2 ,0 00 ro bins per year, an

estimated 0.0 3% 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. Theref ore 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 W A (R MBO 2004). WS could remove 500 eggs a year without affecting the ab undance, distribution, or trend of these species.

4.4.1.2.6 Raptors

Red

- tailed Hawk Population Impacts

The WA re d

- tailed hawk population is estimated to be 47,000 individuals (RMBO

200 4 ) and BB S trend data for the species shows that WA has a n increasing population (Sauer et al. 20 11 ). WA WS harassed an average of 41 , relocated an average of 12 , and killed an average of 10 red

- tail ed 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 remove d 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. T he 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 theBird Damage Management in Washington

- 65

need to trans locat e 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

trans locate bald eagles from an airfield to protect human health and safety ; no eagles were killed by WS during this analysis period . WA WS may trans locate as many eagles as ne cessary and permitted to pr otect public safety on airfields, while also protecting eagles from being killed by aircraft. Trans location and/or harassment of bald eagles at airfields would not negatively impact the abundance, distribution, or trend of the s pecies.

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 a n oscillating, but relatively stable population (Sauer et al. 20 11 ). WA WS harassed an average of 105 and killed an average of 2 5 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 Specie s

An i nvasive 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 Collar e d

- D ove, and European Starling Population Impacts

Feral pigeons , English sparrows , Eurasian collar e d

- 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 t hese 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.

F eral pigeon BBS trend data for WA indicate that their n umbers are increasing (Sauer et al. 2011 ) with a current estimated population of 800 ,000 (RMBO 200 4 ).

WA WS harassed an average of 7,808 and killed an average of 9,101 feral pigeons per year from FY0 6 through FY 10

. As an invasive species, WS could remove as many feral pigeons as necessary to reduce damages to resources, and will conductBird 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 200 4 ). The BBS trend shows English sparrow populations remain relatively stable with annual variations in populations in WA (Sauer et al. 20 11 ). WA WS dispersed an average of 213 and killed a n 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 und er 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 exponential ly increasing in the Western BBS Region (Sauer et al. 2011). WS is

receiv ing 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 a n 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 Europ ean starling population has been estimated to exceed 200 million ( National Geographic 2006 ) and WA has an estimated population of approximately 3,200,000 birds ( R MBO 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 FY0 6 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 predat ory 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

exten t 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 so cietal 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 u sually 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 suf fering. 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 pr obably 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 m ethods 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 hu mans, 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 actio n 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.

Howev er, 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 appr opriate 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 occurBird 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 co nformance 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. A lternative 1 would allow the implementation of lethal remova l 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 be come 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 method s 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 propo se 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 let hal 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 Specie s

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 e ffect 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 exhauste d 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 o r 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 Al ternative 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 preven t 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 damag e 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 (rega rdless 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 les s 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 problem s

.

4.4.3.1 Effects of Methods on Non

- target and ESA

- listed Species

Under this A lte rnative, WS would have no direct e ffect 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 . T he inability to fully predict potential effects from a non

WS 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 couldBird 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 s pecies 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 ha ve 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 u nder 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 A lternative 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

bird s. 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 prov ided 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 enti ties are required by law to conduct wildlife damage management. For example, t he FAA requires certificated airports to implement measures to alleviate or eliminate wildlife hazards to air carrier operations (14 CFR 139.337(d)). Landfills
“demonstrate tha t 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 con tinue to issue Depredation Permits directly to airports and otherBird 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 o ther entities c ould 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 sp ecies. 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

effe cts 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 P roposed A lternative.

4.4.4.2 Effect of Methods on Populations of Target Species

Under this A lternative, 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

wi ldlife 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 P roposed A lternative.

4.4.4.3 Humaneness of Methods

Under this A lternative, WS c ould not recommend or provide practical, effective, and safe methods for reducing bird damage and threats to human health and safety. A s 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 recommend ed by
WS, use BDM me thods incorrectly, or attempt illegal methods

. As such, this

A lternative 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 expertis e 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 n on

- 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 f rom 2006 through

2010. USFWS records data on a calendar year basis,

w hereas 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 low er and does not result in any significant impacts to the

human environment when

co mbined 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.Bird Damage Management in Washington

- 73

No risk to pub lic 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 s afety 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 activitie s 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 as sure 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.Bird Damage Management in Washington

- 74

CHAPTER 5 LIST OF PREPARERS, R EVIEWERS, AND PER SONS 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 PUDBird Damage Management in Washington

- 75

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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

D epredation O rder 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 8Bird Damage Management in Washington

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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 0Bird Damage Management in Washington

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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 186Bird Damage Management in Washington

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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 0Bird Damage Management in Washington

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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 cau sed 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 o ther 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 manage ment 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 m igratory 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

Aviatio n 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 asse ssment 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

- 33 B to guide their decision making process.

The FAA is empowered to issue airport operation certificates to airports serving air carriers, and to

establ ish 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 requ ired to conduct a W ildli f e H azard A ssessment 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 CertA lert No. 97

- 02 further clar ifies 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 mo ve 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

mu lti

- 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 se ts 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. Federa l 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 publ ished 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 altern atives 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 socia l 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 responsibilit y 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 aut horized, 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 (USD I 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 pe rsons 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 recomme ndations 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 depredatio n 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 whenBird 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, an d 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 scien tific 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 Histo rical 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. 80 0.16(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 p hysical 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

- specif ic 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 hazin g 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 nuis ance 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 a ny 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 Amer ican 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

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Appendix B Occupational Safety and Health Act of 1970

. The OSHA of 1970 and its supplemen ting 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 c ontinuing 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 discriminat ion 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 effe cts 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 envi ronmental 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 muc h, 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

- Prote ction 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 p ractices 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 Cli nton, 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 populatio ns 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

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Appendix B Th e 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 o f 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 implementatio n 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 develo pment, 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

- to

date 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 s tate, 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

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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 incor rectly. 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, con ditions 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 i s 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 cost

effective, 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. T rans located 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, personne l 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 o r 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 conc erns 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 t he 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 usin g overhead wires/lines (Fair aizl 1992, Low n ey 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

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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 i n open doorways have been successful in some situations for excluding birds (Johnson

and Gl ahn 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 a nd 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 v isual 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). T he 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 traditional ly avail able 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 200 3 ). 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, battery

powered, 68

- mW, 650

- nm, diode Av ian 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 practica l 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

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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

ad dition 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 incorporati on 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 harass ment 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

i njury or molting of flight feathers.

Drive nets are used to catch molting (flightless) waterfowl. Long net ting form s 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, fun nel, 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 bird s 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 accidentall y 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.

Tri ggering 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 a s 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

t he 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

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Appendix C Cannon nets/rocket nets are normally used for birds such as feral pigeons, gulls, and waterfowl

an d 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 m esh 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 o n 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 i nto 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 consi sting 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 in to 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 th e 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 fo od 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. Met hyl 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.

Anthraq uinone 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

lo w 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 post

ingestional response.Bird Damage Management in Washington

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Appendix C Alpha

- chloralose is a central nervous system depre ssant 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 t ake 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 collec ted 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 v igorously 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 whi ch 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 wh en 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 tr aining 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 c an be used to

r educe 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 effectiv e 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 ca n 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 a nimal 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

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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). Bir ds 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 on ly 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 sen sitive 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, ma gpies 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 probab le 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

man agement 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. 196 6). Studies document ed 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 popul ation 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. DRC

1339 was developed as an avicide beca use 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, mag p ies, and ravens are highly sensitive to DRC

- 1339. Many
other species such as raptors, sparrows, and eagles are c lassified as non

- sensitive. Numero us 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 b lackbirds 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 degradationBird Damage Management in Washington

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Appendix C o ccurs 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 a nd 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 expecte d 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 allo ws 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 sma ll birds (AVMA 2007). Cervical dislocation rapidly induces unconsciousness, does not chemically contaminate the tissue, and is rapidly accomplished (AVMA 2007).

Carbon dioxide (CO 2 ) 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 CO 2 are: 1) its well established rapid depressant, analgesic, and anesthetic effects, 2) its ready availability ( e.g ., can be purchased in compre ssed 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 CO 2 causes little distress to the birds, suppresses nervou s activity, and induces death within 5 minutes. In addition,

inhalation of CO 2 at a concentration of 7.5% increases the pain threshold, and higher concentrations

of CO 2 have a rapid anesthetic effect (AVMA 2007).Bird Damage Management in Washington

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Appendix C Literature Cited

APHIS. 2003. Tech Note: Use of Lasers in Avian Dispersal. USDA/APHIS/WS. 2 pp.

AVMA. 2007. AVMA Guidelines on Euthanasia. Online. http://www.avma.org/issues/animal_welfare/euthanasia.pdf

Blackwell, B.F., G.E. Bernhardt, and R.A. Dolbeer. 2002. Lasers as non

- lethal av ian repellents. J

. Wildl

. Manage

. 66: 250

– 258.

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’Br i en. 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. Sc hafer. 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 depredations. Proc

. Vertebr

. Pest Conf

. 15: 105

– 109.

Fuller

- Perrine, L.D., and M.E. Tobin. 1993. A method for applying and removing bird exclusion netting in commercial vineyards. Wildl

. Soc

. Bull

. 21: 47

– 51.

Glahn, J.F. 1982. Use of starlicide to reduce starling damage at livestock feeding operations. Proc.

Great Plains Wildl. Damage Cont. Work. 5: 273

- 277.

G l ahn, 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 laser to disperse double

- crested cormorants and other birds. U SDA, APHIS , W S ’ N WRC , Fort Collins, Colorado, USA.

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

. Wi l dl

. Damage Manage

. Conf

. 9: 34

– 45.Bird Damage Management in Washington

- 100

Appendix C Johnson, R.J.

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