The California Coastal Commission posted notice on June 21, 2019 of their upcoming public hearing on the Trump Administration’s proposed helicopter dispersal of 1.5 metric tons of poison bait pellets in the Greater Farallones National Marine Sanctuary, located 27 miles off the coast of San Francisco. The proposed poison drop is targeted for this fall.

The Coastal Commission will be conducting a public hearing in San Luis Obispo on July 10, 2019 starting at 9 am at the Embassy Suites Hotel at 333 Madonna Road, to help them reach a decision. Public comments are accepted by email, letter or fax and must be received by July 5, 2019.

We are respectfully requesting that you reject the pending request for a consistency determination on item W14a, USFWS’s poison dispersal plan. As you know, this proposal targets the middle of a treasured State Marine Reserve and would also be right in the midst of our longstanding National Marine Sanctuary within whose waters such activities are expressly precluded. Sanctuary regulations even ban pollutants that “enter and injure” sanctuary resources from outside of the boundary of the sanctuary.

As constituents and admirers of the Greater Farallones National Marine Sanctuary, we are shocked at the proposal to dump 1.5 metric tons of loose rat poison over the South Farallon Islands. This project poses severe risks and will have long term impacts to ALL the living resources within the public trust. USFWS has a legal and moral obligation to protect all of these living resources.

Abandoned by the Obama Administration in 2013 as being too risky to the Sanctuary and a threat to adjacent fragile coastal ecosystems, while also posing unnecessary danger to non-target species, the poison drop proposal here has recently been revived by federal officials, who are now pushing the Coastal Commission to find their scheme to be “consistent” with California’s Coastal Plan.

U.S. Fish & Wildlife Service (USFWS) asserts that burrowing owls from Marin pose a threat to Ashy Storm Petrels, a seabird that frequents the islands, but the same agency has also declined petitions to list the Ashy Storm Petrel as at risk under the Endangered Species Act, noting that their population is on the increase.

USFWS is now claiming that not one single poison pellet will reach the water, a statement that contradicts how the rat poison has been dispersed in previous projects elsewhere. USFWS makes the outlandish statement that they can kill every single mouse on the South Farallon Islands using a slow-acting and highly persistent poison proven to travel up the food chain. Remarkably, USFWS states this is the only way to discourage the small number of burrowing owls (an average of six each year) from migrating to the Farallones to feed on the mice.

The poisons being proposed are the subject of increased scientific scrutiny because of non-target wildlife disasters during similar air drops on island locations elsewhere. The State of California has outlawed retail sale of the same toxic compounds due to the unintended damage they inflict on raptors, mountain lions, bobcats, an iconic mammal called the pacific fisher, and in terrestrial urban interface locations, dangers to pets and children. Legislation severely limiting their use is now moving through the California State Legislature.

Some within the USFWS admit that, at a minimum, 3000 gulls ingesting the poison pellets during a helicopter drop this fall, could return to die in mainland locations they frequent, such as at Fishermen’s Wharf, the San Francisco Zoo and Alcatraz island. The death toll will be substantially higher if the highly questionable hazing program suggested by USFWS fails to keep the gulls away from their territories’ early in the breeding season. Any accidental wind, or wave-borne discharges of the poison into the ocean pose a contamination hazard to fish, crabs, and abalone.