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The Farallon Islands, USFWS, and Island Conservation's Tax-free Government Contracts

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By the time you read this article, a Freedom of Information Act request (FOIA) signed by the Animal Legal Defense Fund, retired USFWS Biologist Sonce DeVries, and me will have been delivered to U.S. Fish & Wildlife in Washington DC. You can find a copy of the press release here.

We are seeking information and details surrounding the business relationship between USFWS and the Santa Cruz based nonprofit, Island Conservation. Since 2008, Island Conservation has been awarded lucrative, tax-free government contracts to conduct pest control on remote islands without any formal bid process, minimal regulatory oversight, and no accountability for past violations of the Migratory Bird Treaty Act, the Bald and Golden Eagle Protection Act or EPA law.

Island Conservation's federal contracts to carry out highly controversial island eradication projects also include payment to write the environmental impact statements and/or assessments for the very projects they will carry out. This explains why their environmental review(s) read more like project plans than an unbiased, neutral analysis.

While NEPA (National Environmental Policy Act) requires all financial interests be disclosed during the environmental review process, Island Conservation's financial arrangement with the U.S. government have never been revealed to the public before.

However, documentation of this conflict of interest was made available on the following Change.org petition, and was published by the Huffington Post in January of this year.

Scientific Misconduct

My article, "The Farallon Island Mouse Eradication Project: the 'Con' in Conservation" was the result of my research into a mouse eradication project that USFWS and Island Conservation have planned for the Southeast Farallon Islands, located 27 miles off the coast of San Francisco. This $1.3 million dollar (at a minimum) federal contract with Island Conservation targets non-native mice; however, the aerial broadcasting of loose rat poison pellets from helicopters over an island wildlife refuge will result in thousands of protected, wild animals being poisoned as "by-kill" or "collateral damage." The risk for contamination of the Farallon food chain and long term epigenetic impacts to the entire ecosystem have been overlooked and dismissed by USFWS, Island Conservation, and Point Blue Conservation Science.

Scientific misconduct is not new to USFWS and has captured the attention of Congress, specifically the Committee on Natural Resources. Chairman Doc Hastings issued this letter last year to USFWS Director Dan Ashe, and this letter to former Secretary of the Interior Ken Salazar expressing his concerns regarding scientific integrity within USFWS. I recently reached out to the office of Chairman Hastings and look forward to engaging with his office.

The rationale given by USFWS to drop 1.3 metric tons of rat poison across the southeast Farallon Islands is to save the Ashy Storm Petrel from possible extinction. Yet, in October of 2013, the USFWS endangered species division denied listing the Ashy Storm Petrel as endangered, their reasoning below:

"The Service has determined that population trend data for ashy storm-petrel indicates that the species is currently undergoing natural population fluctuations and that the species is not in a long-term decline." -- USFWS, Endangered Species Division

The consistent theme in the selling of island eradication projects is to claim that an environmental "crisis" exists and that something must be done immediately! Words like "plague-like" numbers of mice, and "saving species from extinction" are meant to stir up emotions and are part of the marketing pitch that results in the sale of one type of pest control by one contractor, using one type of toxic bait.

Lurking in the background is usually New Zealand's Department of Conservation and their Island Eradication Advisory Service Group selling a variety of consulting services, including the bait and helicopter pilots necessary. Yes, the government of New Zealand is in the business of manufacturing Brodifacoum, 1080, and other horrific poisons via this factory, known as a State Owned Enterprise, which is a private business that the government owns, and profits from.

The Farallon Islands mouse eradication project is the first time such an attempt for mice will be carried out on an island so close to a major metropolitan area. The issue is also complicated by the fact that the failure rate for eradicating mice is 38 percent. Of the last four rat eradication projects, two have been successful, and two are dismal failures. The two that may be "successful" are Rat Island in Alaska and Palmyra Atoll in the Pacific. The term "successful" is questionable since the "success" is determined solely by the group doing the eradication -- Island Conservation.

No independent, third party auditor monitors the full ecosystem impacts of applying unprecedented volumes of one of the most deadly pesticides to wildlife since DDT, or confirms any of the claims of success made in press releases.

While Island Conservation and USFWS state that Rat Island is a success, there is no way to confirm this or know what the true numbers are in terms of wild animals that were inhumanely poisoned. This scathing report from the Ornithological Council identified a number of blunders made during the Rat Island eradication that led to the discovery, eight months after the poison drop, of 46 dead bald eagles and over 420 birds. Since the counting of dead animals was made by Island Conservation eight months later, the public will never know how many animals actually perished, what the level of contamination was in the offshore marine environment, or if future generations of wildlife will suffer long-term affects from exposure to sub-lethal levels of brodifacoum.

The two recent failures are Wake Island in the Pacific and Desecheo Island in the Caribbean. Both cost millions of dollars, and killed unknown numbers of wildlife in the process. The Wake Island eradication is now being repeated by USDA Wildlife Services. Desecheo Island will doubtless be repeated as well, providing additional revenue to Island Conservation. This "repeat business model" is a sweet deal for Island Conservation, and the icing on the cake is that all revenue earned is tax free!

The Marketing of Island Eradication Projects by USFWS

The marketing strategy USFWS has embraced for island eradication projects is to continually refer to the country of New Zealand, specifically the Department of Conservation (DoC), as having expertise and success in carrying out these projects. The practice of using helicopters to carry out poison drops (be it brodifacoum or 1080) is only done by the government of New Zealand. No other country in the world engages in this macabre practice that is driven by a business model that demands that an invasive species "crisis" be manufactured whenever money runs low. As mentioned, money is also generated by New Zealand's export of these services around the globe. There is a close working relationship between New Zealand's DoC and Island Conservation, as former employees of DoC are now employed by Island Conservation.

Who is Paying for All of This? (Hint... it's the taxpayer!)

Projects like these are expensive, usually surpassing the million dollar mark. Research shows a huge range in cost from $1 million to $25 million dollars, depending on the size of the island. Not surprisingly, a consistent theme in the funding source has surfaced. Rat Island, Desecheo, Wake Island and Anacapa Island are all previous island eradication projects performed by Island Conservation with various amounts of input from USFWS. Each of these projects have received funds from USFWS through various funding mechanisms.

Department of the Interior, Office of the Inspector General Report, June 2011

This disturbing report from the Office of the Inspector General (OIG) was the result of an audit in which the OIG evaluated how grants and cooperative agreements were administered by USFWS through the Pacific Islands Fish and Wildlife Office (PIFWO) to nonprofit organizations. In this document, the OIG sounds the alarm regarding the administration of grant money and cooperative agreements.

Throughout this report the words fraud, conflict of interest, and favoritism are frequently used to describe what the OIG found during their investigation.

Specific nonprofits are not mentioned in the OIG's report. However, it is worth mentioning that the Hawaii office for Island Conservation is located within the Honolulu office of USFWS.

"We found that in administering grants and cooperative agreements, PIPWO did not meet its fiscal responsibilities while the Pacific Regional Office failed to provide effective oversight. Ineffective implementation controls, together with numerous ethical concerns and fraud indicators, placed USFWS at significant risk for favoritism and fraud. In this environment, undisclosed relationships between USFWS grant administrators and recipients raised the appearance of conflicts of interest. In light of these concerns, we set out to determine what, if any, improper acts may have taken place and questioned whether nearly $1.1 million of grant funds were awarded inappropriately as a result of breaches of ethical standards and a disregard for administrative requirements of financial assistance programs." ~ June 2011 report, DOI, Office of the Inspector General

U.S. Oil Spill Money Pays for a Pest Control Project in New Zealand

One island eradication project in New Zealand was even paid for by U.S. oil spill money! The Tank Vessel Command oil spill off the coast of California in 1998 resulted in the settling of a Natural Resource Damage claim of approximately $4 million dollars. According to federal law, the money awarded for damages from this spill can only be used for projects designed to restore the damages caused by the spill. Half a million dollars ended up being used to eradicate rats on New Zealand islands to "save" the sooty shearwater, eleven of which were retrieved during the spill. It is important to note that the sooty shearwater is not even at risk! The population of this bird currently numbers worldwide at about 21 million (Newman et al.2009) and, one of the biggest threats to the population is unlimited take of the fledgling chicks by New Zealand locals who take only the biggest and fattest, the very ones that have the best chance of survival and replenishing the population.

Freedom of Information Act (FOIA) Request with Animal Legal Defense Fund

What details will our FOIA request reveal? Only time will tell as we wait to receive the information requested, and try to anticipate the decision by USFWS as to whether or not they choose to move forward with a project that is absent of scientific integrity, is infested with major conflict of interest issues and opposed by over 28,000 people from around the world.

"Once again animal suffering goes hand in hand with human profit. With such
massive death counts and millions of taxpayer dollars at stake, this is when
government transparency is most important. ALDF looks forward to a swift and
thorough response to shed light on the systematic poisoning of our wildlife and
wild spaces." ~ Stephen Wells, Executive Director, Animal Legal Defense Fund

I would like to express my heartfelt gratitude to retired USFWS biologist Sonce DeVries, and my colleagues in New Zealand; Bill Benfield, Clyde Graf and Paul Tucker for their contributions to this story.

NEXT UP: Stories from censored conservationists in New Zealand fighting a much bigger battle. Until then, this powerful photo essay done by the Graf Boys gives just a glimpse of what routinely happens in New Zealand when helicopters are used to indiscriminately disperse poisons over wilderness areas. Warning: Some may find these images of poisoned wildlife disturbing.

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