Title: Decision notice and finding of no significant impact : sustained reduction plan for non-native goats and sheep within Virgin Islands National Park
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Title: Decision notice and finding of no significant impact : sustained reduction plan for non-native goats and sheep within Virgin Islands National Park
Alternate Title: Sustained reduction plan for non-native goats and sheep within Virgin Islands National Park
Physical Description: Book
Language: English
Creator: United States. National Park Service.
Virgin Islands National Park ( Contributor )
Publisher: United States. National Park Service.
Publication Date: 2004
 Subjects
Subject: Caribbean   ( lcsh )
Spatial Coverage: North America -- United States Virgin Islands -- Saint John -- Virgin Islands National Park
Caribbean
 Record Information
Bibliographic ID: CA01300645
Volume ID: VID00001
Source Institution: University of Florida
Holding Location: University of Florida
Rights Management: All rights reserved by the source institution and holding location.

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FINDING


DECISION NOTICE
AND
OF NO SIGNIFICANT IMPACT


SUSTAINED REDUCTION PLAN
FOR
NON-NATIVE GOATS AND SHEEP
WITHIN
VIRGIN ISLANDS NATIONAL PARK


U. S. D. I. National Park Service
Virgin Islands National Park
St. John, U. S. Virgin Islands



INTRODUCTION

This Decision Notice (DN) and Finding of No Significant Impact (FONSI) documents the decision of the
National Park Service (NPS) to adopt an Environmentally Preferable Alternative program for the
sustained reduction of non-native domestic goats and non-native domestic sheep within Virgin Islands
National Park (VINP), and determines no significant impacts on the human environment are associated
with the decision.

The FONSI is based upon a Draft Environmental Assessment (EA) released in December 2003, and
comments of agencies and the public on the EA. The purpose of the EA was to evaluate the effects of a
proposed sustained reduction program for goats and sheep, both of which are non-native, from within
Virgin Islands National Park. The EA has been prepared in accordance with the National Environmental
Policy Act (NEPA) and NPS policy and guidelines. The Draft and Final EA's were available for public
review at the following locations:


Visitor Center
Virgin Islands National Park
St. John, VI

Enid M. Baa Public Library
St. Thomas, VI


Elaine I. Sprauve Public Library
St. John, VI


National Park Service Headquarters
Christiansted; St. Croix, VI


The Final EA may also be viewed at www.nps.gov/viis or www.friendsvinp.org. Printed or electronic copies
of the Final EA can be requested from the National Park Service at (340) 693-8950 extension 224 or at
Rafe Boulon@nps.gov.

The NPS decision is to select Alternative 2 in the Final EA.


DECISION NOTICE AND FONSI
SUSTAINED REDUCTION PLAN FOR NON-NATIVE GOATS AND SHEEP
Virgin Islands National Park
July 2004










BACKGROUND


People have accidentally or intentionally introduced hundreds of non-native species into natural
communities worldwide, and while many die out, some persist and become pests. It is now widely
accepted the current species extinction rates are dramatically higher than background rates; most current
extinctions can be directly attributed to human activity; and for ethical, cultural, aesthetic and economic
reasons, the current extinction rate is cause for considerable concern. Human-caused extinctions can be
roughly divided into four broad categories: non-sustainable use of resources, habitat destruction,
pollution, and introduced non-native species.

Results of the first three categories are often acute and directly affect human and native wildlife welfare
on an observable time scale. Human-related impacts have made them the focus of public environmental
concern. The introduction of non-native species has received less publicity and scientific attention;
however, introduced species are responsible for 39% of all recorded animal extinctions since 1600 for
which a cause could be attributed (Treshy and Croll 1994). Thus, some introduced species impacts are
irreversible and equally devastating compared with other categories. Once established, introduced species
often become permanent ecological features until their intentional removal.

Native wildlife in island ecosystems is particularly vulnerable. Of the 484 recorded animal extinctions
since 1600, 75% have been island endemics. Introduced species were completely or partially responsible
for 67% of these extinctions (based on the 147 island species for which the cause of extinction is known).
Islands are also important for the conservation of biodiversity, as well (World Conservation Monitoring
Centre 1992).

Impacts to native plants and native plant communities from goats and sheep have been well documented
in the literature and those impacts would continue to affect island vegetation including endemic and
federally listed plant species (Baker and Reeser 1972: Coblentz 1978 and 1980; DieterSpatz et. al. 1973;
Katahira and Stone 1982; Mueller-Dombois et. al. 1975; Scowcroft and Hobdy 1987; Stone et. al. 1992;
Stuht 2001; Taylor and Katahira 1988; and Yocum 1967).

Non-native goats and sheep have established breeding populations throughout all habitat types of the
Park. Many wildlife ranchers keep goats and sheep in herd sizes ranging from a few animals to several
dozen. Small herds of sheep sometimes mix with goat herds, but sheep are considerably less common
than goats. The Park has experienced goat and sheep grazing.

The original areas of goat encroachment included: portions of Leinster Bay near the Johnny Horn Trail;
Bordeaux Mountain area above and including much of the Lameshur watershed; the East End near the
NPS Firing Range; the upper-eastern portion of Hawksnest Bay; and the Ram Head area. By the early
1990s, free ranging goat herds were established in Mary's Point and Brown Bay. In 1999, 5 goats were
abandoned at Lind Point. Finally, in the summer of 2000, approximately 12 goats were abandoned on the
North Shore Road immediately inside the Park boundary above Cruz Bay. Sheep have occurred within
large goat herds at Brown and Leinster bay since the late 1990s.

In FY 2000, Virgin Islands NP installed about 100 animal-proof trash containers (at a cost of about
$75,000) at all Park sites except the major concession operations at Trunk Bay and Cinnamon Bay to
collect refuse. In 2002, the NPS spent $30,000 to purchase and install an additional 20 animal-proof trash
containers at major concession locations (eight at Trunk Bay and twelve at Cinnamon Bay) to collect
refuse. Also in 2002, NPS constructed a one mile long donkey exclusion fence with four barbed-wire


DECISION NOTICE AND FONSI 2
SUSTAINED REDUCTION PLAN FOR NON-NATIVE GOATS AND SHEEP
Virgin Islands National Park
July 2004










strands around the perimeter of the Cinnamon Bay Campground at an estimated cost of $67,000 but not
designed to exclude goats or sheep. A design necessary to exclude goats and sheep was prohibitively
expensive; donkeys were the non-native animals causing the greatest campground problems.


PUBLIC INVOLVEMENT

Implementation of the preferred alternative from the EA could affect Park visitors, commercial operators,
island residents, the integrity of natural and cultural resources, and the status of listed threatened and
endangered species. Therefore, public participation was a critical element in the preparation of the EA.
The public involvement process for the EA provided three distinct phases of public information: (1)
scoping of issues to be analyzed in detail in the EA, (2) Draft EA, and (3) Final EA.

The Draft EA was released for 60 days of public review on December 15, 2003, with a press briefing
conducted in conjunction with its release. Public review opportunities included:

A public scoping meeting was held at the Legislative Conference Room on August 12, 2003.
Personnel from the Territorial Government of the United States Virgin Islands (USVI) attended
including the Virgin Islands Department of Agriculture (VIDA), and the Department of Planning
and Natural Resources (DPNR); Friends of the VINP and the St. John Community Foundation, as
well as several media representatives. About 40 persons attended the two-hour meeting.
Various discussions between the NPS and VIDA, DPNR, and VI Police Department (VIPD), and
the University of the Virgin Islands (UVI) Cooperative Extension Service, regarding livestock
regulations in the USVI.
Distribution of more than 30 copies of the Draft EA.
Providing a printed copy of Draft EA in libraries on St. Croix, St. Thomas and St. John.
Developing news stories describing the effects of exotic animals to VINP's wildlife, flora and
cultural resources published in the Park paper and several local newspapers and radio stations.
Briefings with NPS staff, Friends of VINP, staff of the USVI Department of Planning and Natural
Resources, USVI Department of Agriculture, and other key community leaders and interest
groups.
Posting of the Draft and Final EA and newsletter summary on the web sites for VINP and the
Friends of the VINP.

Two comments were received during the public review period for the Draft EA. Issues included:

general comments of support
use of fertility control
boundary fence installation and maintenance by private livestock owners
the mosaic of Park and private lands
use of dogs to locate animals
use of live traps preferentially over kill traps
use of leg snares to trap animals
how collected animals will be euthanized and,
removal of goats to a United States wildlife sanctuary.


DECISION NOTICE AND FONSI
SUSTAINED REDUCTION PLAN FOR NON-NATIVE GOATS AND SHEEP
Virgin Islands National Park
July 2004










Based upon comments on the Draft EA, modifications were made to the Preferred Alternative. NPS
responses are provided in an errata sheet to this DN/FONSI.


ALTERNATIVES ANALYZED

Range ofAlternatives

Two alternatives, including the "No Action, Continue Current Level of Management" Alternative and the
NPS Preferred Alternative, were analyzed in detail in the EA. These alternatives were developed from
issues raised in internal and public scoping, and based upon the purpose and significance of VINP. Five
alternatives were considered but eliminated from detailed analysis in the Draft EA. The EA discloses the
potential environmental consequences that may result from implementation of various alternative
management strategies. Comments received during public review of the Draft EA were considered in
preparation of a Final EA and this FONSI/DN.

Alternative 1. No Action, Continue Current Level of Management. Under Alternative 1, non-native
goats and sheep would continue to flourish unabated throughout VINP. No reduction efforts would be
used on goats or sheep within VINP. Their population numbers would continue to rise with the
availability of food resources and the documented trend to move into new areas would continue within
VINP. Impacts to native plants and native plant communities from goats and sheep have been well
documented in the literature and those impacts would continue to affect island vegetation including
endemic and federally listed plant species (Baker and Reeser 1972: Coblentz 1978 and 1980; DieterSpatz
et. al. 1973; Katahira and Stone 1982; Mueller-Dombois et. al. 1975; Scowcroft and Hobdy 1987; Stone
et. al. 1992; Stuht 2001; Taylor and Katahira 1988; and Yocum 1967). Under the No Action alternative,
NPS would continue to animal-proof trash receptacles, dumpsters and buildings at campgrounds, day use
sites, concession areas, Park overlooks, and employee housing areas and collect trash on a regular basis.


Alternative 2. Reduce Goats and Sheep within VINP and Sustain a Near-zero Population, the NPS
Selected Alternative. Under Alternative 2, the NPS Preferred Alternative in the EA, non-native goats and
sheep will be controlled within VINP lands on St. John, Hassel Island, and St. Thomas, (should goats or
sheep move into NPS property on St. Thomas). The goal will be to humanely and substantially reduce
their population throughout the Park, and sustain the reduction to zero or near-zero through monitoring,
periodic removals, selective fence installation and maintenance, and ongoing information dissemination
through partnerships with governmental and non-governmental organizations.

Because fewer than 50 sheep live in the park, a majority of collection techniques will be applied
exclusively to goats. Throughout the Draft and Final EA, goats and sheep are mentioned together,
however goats are in the majority; since both species exist in (some of) the same herds, treatment for both
in a single compliance document and control plan was logical. A central theme of the control plan is to
routinely educate residents, visitors, wildlife ranchers, NPS employees and concessionaires. A
comprehensive methodology is preferable to a single control method for efficient, humane application
throughout remote, diverse and challenging subtropical habitat types and extremely steep topography.
Particular emphasis will be placed on preventing new animals from entering the park, as well as
compliance with the VIDA Animal Registration and Impoundment Program. Over time, more resources
will be focused on preventing non-native wildlife encroachment into the Park, instead of removal from
the park. Initial control efforts focus on both removal and prevention. Sustained partnerships and their
periodic renewal, both formal and informal, are crucial themes for a successful, long-term program, and

DECISION NOTICE AND FONSI 4
SUSTAINED REDUCTION PLAN FOR NON-NATIVE GOATS AND SHEEP
Virgin Islands National Park
July 2004










recur throughout the EA. These coalitions are necessary to ensure routine education and information
development and dissemination.

The NPS and the United States Department of Agriculture (USDA) Animal Plant Health Inspection
Service (APHIS) Wildlife Services (WS) Division, as lead cooperating agencies, will conduct the initial
reduction of non-native goats and sheep. Each agency will have a Program Coordinator and this team
will manage and supervise the program. VIDA and DPNR will play advisory roles to plan and implement
the reduction, mitigation and monitoring components of the program. VIDA through a Memorandum of
Understanding (MOU) with the NPS will provide a valuable role to live trap and remove goats and sheep
from VINP under the direction of the NPS/APHIS Program Coordinators. The NPS will assist VIDA to
implement and promote the VI Animal Registration and Impoundment Program. All personnel involved
with this program will follow the measures described in the FONSI: for the safety of island residents,
visitors and wildlife personnel; the humane capture and euthanization (if necessary) of goats and sheep,
and; for the protection of natural, cultural and wetland resources.

Prior to implementing a Park-wide goat and sheep reduction program, goat and sheep ranchers will be
requested by letters and press releases to remove their livestock from within VINP. Ranchers will be
required to remove their animals within a 60-day period before implementation of the direct reduction
program. Following this 60-day amnesty period, goats or sheep residing within the Park will be
considered abandoned, and subject to collection to protect the Park's vegetation, wetland and cultural
resources from the negative effects of free-ranging livestock (Code of Federal Regulations, Title 36, Part
2.15(5)(c): pets or feral animals). The Virgin Islands Code, Title 19, Section 2616 (a): "any animal found
running at large, or tied on public property or on private property without the consent of the owner of said
property, shall be taken up by animal wardens and impounded in an animal shelter, and there confined for
disposition in accordance with the provisions of this subchapter."

The primary tools for goat and sheep collection include live traps, relocation and invariably some
shooting. Limited use of tracking ("baying") dogs, snares and "Judas" goats represent secondary
reduction methods, which may be considered at a future time if primary methods fail to reduce the goat
populations. During the peak period of the goat and sheep reduction program, there will be an increase in
personnel on St. John Island of 2 to 4 people. However, they will be the same individuals contracted by
the NPS to implement the sustained reduction of non-native hogs from VINP. They will be housed
generally in government housing on NPS property. A standard-sized pickup truck will be the primary
mode of transportation. All-terrain vehicles may be used incidentally for transportation, one or two
horses may be considered for limited field operations in the future. Temporary tent camps may be
established to facilitate operations in remote areas; minimal and ephemeral impacts are possible and the
resident NPS Archeologist will authorize the sites on a case by case basis.

The techniques and tools for achieving the reduction goals are consistent with goat and sheep reduction
models on Santa Rosa Island and Santa Cruz Island (NPS 2001) in Channel Islands National Park and
Hawaii Volcanoes National Park (NPS 1999).

The goal will be to reduce substantially goat and sheep populations within VINP and sustain a near-zero
population. This will be accomplished through a three-phase approach. In the first phase, administration,
infrastructure acquisition, and selective fencing may occur along sections of the boundary. In the second
phase, techniques such as baits, traps, and shooters will be used to reduce populations throughout the
Park. In the third phase, the NPS will monitor for and periodically remove remnant goats and sheep,
provide resource education, community outreach, information dissemination, and record keeping,
maintain fences and renew formal partnerships.


DECISION NOTICE AND FONSI 5
SUSTAINED REDUCTION PLAN FOR NON-NATIVE GOATS AND SHEEP
Virgin Islands National Park
July 2004










Phase I will require approximately one year to complete once completing environmental compliance.
This year will be used to hire or contract with personnel, purchase supplies, construct traps, establish
communications, and possibly fence some of the most vulnerable long-term monitoring plots. NPS may
also begin selective fencing near limited areas of the boundary where goats and sheep can easily reenter
the Park (Herman Farm, L' Esperance and Catherineberg, Bordeaux Mountain, Hawksnest, Cinnamon,
Ram Head and Lameshur) if well-used wildlife trails can be found. Funds may be made available for
island livestock ranchers to install or repair their fences during Phase I or in the future.

A relatively fast initial goat and sheep population reduction campaign is envisioned in Phase II, possibly
approximately 2 to 3 years. Baiting in conjunction with snares, single-capture and corral-style live-traps
may be employed throughout each targeted watershed. A majority of animals are expected to be live-
trapped and removed. These will be released to local wildlife ranchers who comply with territorial
animal registration requirements; and some will be utilized for personal consumption. Areas of high goat
(and to a much smaller degree sheep) concentrations such as Brown, Leinster Lameshur and Reef bays,
Hurricane Hole, and Ram Head, will be selected for initial animal removal. Areas with small populations
will also be selected for initial removal efforts such as Lind Point, Mary Creek, Hawksnest and
Cabrittehom Point. Goat and sheep movements will determine where the collection efforts must then be
focused. Biological and ecological data will be recorded from each animal. Local volunteers may assist
contractors in various control efforts.

Phase III will be an indefinite period of scheduled and systematic monitoring throughout NPS land for
goat and sheep signs. Monitoring efforts for the presence or absence of goats and sheep is crucial to
locate and humanely remove animals from throughout the Park, and protect the sensitive natural, cultural
and wetland resources. If goat, sheep or their foraging and trampling signs become evident in an area,
authorized and certified NPS and (possibly) VIDA personnel will humanely remove the animals as
described in Phase II. An extensive and comprehensive public education campaign is necessary with key
government and NGOs to accomplish the long-term program objectives. During this phase of indefinite
duration, the focus will shift to preventing non-native wildlife encroachment and if successful, few
animals will require control from within VINP.


Environmentally Preferable Alternative

In accordance with Council on Environmental Quality (CEQ) regulations, Alternative 2 is identified as
the Environmentally Preferable Alternative. The Environmentally Preferable Alternative is defined by
CEQ as the alternative "that will promote the national environmental policy as expressed in NEPA's
Section 101. Generally, this means the alternative causing the least damage or most benefit to the
biological and physical environment and best protects, preserves and enhances historic, cultural and
natural resources" (46 CFR 18027, Forty Most Asked Questions Concerning CEQ's NEPA RL g!,i,,li ,,).

Section 101(a) of NEPA recognizes the importance of environmental quality to the overall welfare of
man, and declares a continuing policy to promote conditions under which man and nature can exist in
productive harmony. Section 101(b) establishes a continuing responsibility for the Federal government to
improve and coordinate Federal plans, functions, programs and resources to:

fulfill the responsibilities of each generation as trustee of the environment for succeeding
generations;
ensure for all Americans safe, healthful, productive, and aesthetically and culturally pleasing
surroundings;

DECISION NOTICE AND FONSI 6
SUSTAINED REDUCTION PLAN FOR NON-NATIVE GOATS AND SHEEP
Virgin Islands National Park
July 2004










attain the widest range of beneficial uses of the environment without degradation, risk of health or
safety, or other undesirable and unintended consequences;
preserve important historic, cultural, and natural aspects of our national heritage and maintain,
wherever possible, an environment supportive of diversity and variety of individual choice;
achieve a balance between population and resource use to permit high standards of living and a
wide sharing of life's amenities; and
enhance the quality of renewable resources and approach the maximum attainable recycling of
depletable resources.

According to NPS policy (Director's Order 12), the Environmentally Preferable Alternative is the
alternative to best promote the national environmental policy expressed in NEPA Section 101(b), which
includes alternatives to accomplish the goals from this section (listed above).

Because, in comparison to Alternative 1, Alternative 2 better restores the natural conditions throughout
the park, it is considered the Environmentally Preferable Alternative. Alternative 2 best responds to NPS
mandates to preserve and protect unimpaired the significant resources for which VINP was established,
and allows for appropriate use and enjoyment by the public. Potential adverse effects on natural and
cultural resources will be reduced over those in the No Action Alternative. By reducing the population of
non-native goats and sheep inside the Park, adverse impacts on visitors, residents and natural and cultural
resources will decrease. The proposed reduction program will produce minimal or no damage to Park
resources or threats to visitor or employee safety. Collectively, goat and sheep populations pose a large
threat to the native natural resources, long-term resource management programs of the Park, NPS
mandates, and the health and safety of park visitors.

The Environmentally Preferable Alternative will cause the least damage to the biological and physical
environment and best protect, preserve and enhance the Park's historic, cultural, natural and wetland
resources. Alternative 2, best fulfills the NPS statutory mission and responsibility; best meets the purpose
and need for a Sustained Reduction Plan for Non-native Goats and Sheep; best responds to the issues
identified through public and agency scoping; and achieves the best balance of environmental protection,
visitor experience, public safety, economic well-being and other factors.


DECISION AND RATIONALE

Rationale

With the exception of bats, the VINP is presently inhabited by numerous species of non-native mammals
which produce severe impacts on many indigenous plant and animal species, visitor threats, and
compromise resident and employee safety (Appendix B). Feral or wild mammals include white-tail
deer (Odocoileus virginianus), donkey (Equus asinus), domestic goat (Capra hircus), wild hog (Sus
scrofa), domestic sheep (Ovis aries), cattle (Bos taurus), West Indian mongoose (Herpestes
auropunctatus), tree rat (Rattus rattus), Norway rat (Rattus norvegicus), house cat (Felis catus),
domestic dog (Canisfamiliaris), and house mouse (Mus musculus). Many, if not all of these species, also
threaten visitor experience, health and safety. Increasing populations of these species are seriously
affecting native species of plants and animals. Additionally, introduced species of birds, amphibians,
reptiles, insects and plants are affecting the fragile environment (see Appendix B, List of Introduced
Animals to St. John Island).



DECISION NOTICE AND FONSI 7
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Virgin Islands National Park
July 2004










Large numbers of native flora and fauna are threatened each year to relatively small non-native goat and
sheep populations. Small islands typically have both smaller resident wildlife populations and lower
species diversity. This is particularly true on very small and highly fragmented islands such as St. John,
because most negative impacts are concentrated and accelerated when compared with similar impacts to a
larger landmass. Therefore, the cumulative impacts associated with these increasing wildlife threats are
substantial.

The NPS is mandated to remove animals determined to be injurious to native flora and fauna.
Management of populations of exotic plant and animal species, up to and including eradication, will be
undertaken whenever such species threaten Park resources or public health and safety (NPS Management
Policies 2001, Page 4.4.4.2). High priority will be given to exotic species management with substantial
impacts on Park resources, and those who can feasibly be controlled (NPS Natural Resources
Management Guideline 1991, Chapter 2, Page 286).

A single, rapid population reduction effort is necessary to reduce the present populations to an acceptable
level. Because additional non-native goats and sheep can enter the Park from adjacent lands on public
roads, an acceptable population size (limit) must be established. The population must be periodically
censused or threshold visual estimators developed to ensure the program goals are achieved.

Eradication is impractical and impossible as a feasible alternative due to the size of St. John and the large
number of inholdings. Therefore, efforts will focus on sustained control of the non-native goat and sheep
populations and a concomitant reduction in their impacts on natural and cultural resources. To achieve
this goal, a combination of techniques will be initiated in three phases. In Phase I, administration,
infrastructure acquisition, and selective fencing will be employed. Phase II requires techniques to
humanely reduce populations throughout the Park. Phase III includes indefinite monitoring, partnership
renewal, education and periodic removal; with a central focus to prevent future encroachments


Decision

The NPS decision is to select "Alternative 2, Reduce Goats and Sheep within VINP and Sustain a Near-
zero Population," as described in the Final EA. The NPS in cooperation with the USDA's Animal Plant
Health Inspection Service / Wildlife Services Division, and the VIDA will conduct a site-specific non-
native goat and sheep population reduction program using a combination of trapping, shooting and
fencing within VINP. The goal will be to substantially and humanely reduce non-native goat and sheep
populations within the Park, and to sustain near-zero populations. This will be accomplished through a
three-phased approach (a complete description of the implementation plan is found on pages 19 to 27 of
the Final EA). Under this NPS Preferred Alternative, the sustained reduction program will occur in the
three phases detailed below.


Phase I Administration, Infrastructure Acquisition and Selective Fencing (Approximately 1
year)

This phase will require approximately one year to complete once environmental compliance is met. This
year will be used to hire or contract with personnel, purchase supplies, construct traps, establish
communications, and fence especially vulnerable long-term monitoring plots. NPS may also begin
selective fencing near limited areas of the boundary where goats and sheep can easily reenter the Park.


DECISION NOTICE AND FONSI 8
SUSTAINED REDUCTION PLAN FOR NON-NATIVE GOATS AND SHEEP
Virgin Islands National Park
July 2004










Funds may be sought for island livestock ranchers to install or repair their fences.

Consensus building was established before and strengthened during the NEPA process, continues into
Phase I and must be sustained indefinitely. A strong bridge will be maintained between the NPS, USDA-
Wildlife Services and VIDA. Key groups or officials may reinforce this crucial bridge, including Friends
of VINP, the St. John Community Foundation, VI Department of Planning and Natural Resources, the
University of the Virgin Islands Cooperative Extension Service, the Environmental Association of St.
Thomas and St. John, the St. John Rotary Club, and the Island Administrator.

Fences may be constructed to exclude non-native animals from specific long-term vegetation monitoring
plots and limited selective areas of the boundary where goats and sheep easily reenter the Park from
nearby private livestock ranches. For example Herman Farm, L' Esperance, Catherineberg, Bordeaux
Mountain, Hawksnest, Cinnamon, Ram Head and the Lameshur areas may be considered if wildlife
trails are present (see page 20).

Non-governmental organizations (NGOs) with guidance and assistance from the NPS and USDA-APHIS
will develop a comprehensive community outreach strategy. This outreach serves to inform, advise and
educate the St. John community and island visitors about goats and sheep and the ecological damage a
small group of goats and sheep can inflict on a small, remote subtropical island. VIDA and the University
of the Virgin Islands Cooperative Extension Service will play a key role with the NPS to prepare and
disseminate information in an ongoing basis. One focal point of this informational campaign will be the
VIDA Animal Registration and Impoundment Program. The community will be advised of the global
problems germane to introduced goats and sheep as well as the potential economic loss to the U. S. Virgin
Islands if no action is taken to reduce their populations inside VINP.

The necessity of a long-term monitoring plan to humanely and periodically remove goats and sheep from
the Park will be emphasized. The importance of preventing or minimizing new feral animal
introductions, cessation of feeding activity for dry soils within the Park and other general conservation
measures will be emphasized. Once the NPS/USDA team develops this program with key NGOs (such as
Friends of VINP, St. John Community Foundation, and the Environmental Association of St Thomas and
St. John) it is envisioned these partnership will share in the ongoing development and determination of
information.


Phase II Collection Using Baits, Live -Traps and Contract Hunters (2 to 3 years)

Initial scoping and observation conducted in Phase I and before will allow Program Coordinators to
determine where to concentrate their resources. Several primary control methods including use of baits,
live-traps and contract hunters comprise initial reduction efforts. Secondary reduction methods may
include radio-telemetry, tracking "baying" dogs, snares, and "Judas" goats to humanely collect additional
goats in Phase II or III as they become trap-shy. Because goats are highly social animals, one equipped
with a radio transmitter can lead field personnel to remote locations where other goats congregate. As
goats become trap shy and less common, Program Coordinators (APHIS/NPS) may use bait stations to
capture goats. A majority of collected animals will be donated through VIDA to ranchers, or processed
for utilization (humane euthanization and subsequent butchering for personal consumption). In
extremely remote areas some goats may be euthanized and treated with lime to facilitate decomposition,
or (in exceptionally rare instances) buried at sea. Please see Final Disposition and Use of By-products on
page 23 of the EA. Fence installation may be completed in areas designated for selective fencing while


DECISION NOTICE AND FONSI 9
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Virgin Islands National Park
July 2004










minimizing damage to cultural sites and structures. Reasonable efforts will be made to utilize collected
goats wherever possible and practical throughout VINP and the entire project area.

A relatively fast initial goat and sheep population reduction campaign is envisioned. Phase II will occur
over approximately 2 to 3 years. Baiting in conjunction with single-capture and corral-style live-traps
will be employed throughout selected areas of VINP. Biological and ecological data will be recorded
from each collected animal. These data, field observation records and scat and track analysis will help
determine relative abundance, to establish a baseline from which to estimate and measure group
population dynamics. This phase works closely with VIDA to ensure wildlife ranchers who receive
captured goats comply fully with the Livestock Registration and Impoundment Program. Other
governmental and NGO partnerships/coalitions will be formally and informally renewed and
strengthened. A comprehensive public information campaign will be developed and implemented with
one recurring theme directed at preventing future non-native animal encroachments into VINP.


Phase III Monitor and Removal of Remnant Goats and Sheep, Community Outreach and
Education, Partnership Renewal, Fence Maintenance, and Record Keeping (Ongoing,
Indefinitely)

This phase will be an indefinite period of scheduled and systematic monitoring throughout VINP for goat
and sheep sign. Monitoring efforts for the presence or absence of goats and sheep is crucial to routinely
locate and remove animals from the Park, and protect sensitive natural, cultural and wetland resources.
Water sources, which are preferred habitat for goats and sheep, historical locations of high population
densities, and NPS lands near private livestock ranches, serve as key monitoring areas.

Resource managers will be the lead personnel to accomplish the program objectives and provide
continuity for implementing this plan. If goats, sheep or their foraging and trampling sign become
evident in an area, authorized and certified NPS Law Enforcement or Resource Management personnel
will trap or humanely collect the animals as described in Phase II. VIDA will be sought for their
assistance. Long-term ecological monitoring to assess ecosystem change due to goat and sheep reduction
will continue indefinitely.

NPS Law Enforcement and Interpretation Rangers, Maintenance and Resource Management personnel
performing routine fieldwork will be provided with "Introduced Species Observation Sheets." These
personnel will be instructed on the species of particular concern and the importance of reporting any
suspected sightings, sign or activity, and be routinely notified by Resource Management personnel to
submit documented sightings as soon as possible.

Two possible fence uses are described in this alternative: (a) selectively fencing critical NPS boundary
locations near existing livestock ranches; and (b) fencing some long-term vegetation monitoring plots.
Areas with established non-native wildlife trails may be considered for either fencing option. VINP
personnel will monitor the selective boundary fence and long-term vegetation exclosure fences
approximately every 6 and 12 months, respectively. These workers will also monitor throughout the Park
using transects for goat and sheep sign. Monitoring for encroachment will be intensive where goat and
sheep concentrations were historically high, and in areas near private livestock ranches. Detailed records
will be compiled from these monitoring efforts and maintained in an Excel non-native mammal database.

The partnerships and community outreach established before and during the NEPA process in Phase I will
be supported, maintained and strengthened as key personnel change. Consistent, ongoing education and

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cooperation will be central outreach themes, with emphases on the efforts to routinely provide this
information to the resident and visiting public. Dissemination will occur through the development of
printed and electronic media. In concert with VIDA, the Cooperative Extension Service of the University
of the Virgin Islands, and other partners, the NPS will continually work with goat and sheep ranchers to
maintain goats and sheep on private property; and emphasize the importance of the VIDA Animal
Registration and Impoundment Program. Other governmental (e.g. DPNR) and NGO (e.g. Friends of
VINP, the St. John Community Foundation, the Environmental Association of St. Thomas/St. John, et al),
partners will be used to systematically disseminate the information previously developed to continually
educate the public about non-native animals and their impacts to natural, cultural and wetland resources.

The MOU between VIDA and VINP will be revisited annually with periodic progress reports and
scheduled meetings to refresh and strengthen the partnership. A new MOU will be implemented upon the
expiration of the current document in 2008. Partners mentioned above may eventually be folded into the
existing condition. This effort will combine human and equipment resources to enhance efficiency and
strengthen the participants resolve to humanely and routinely remove animals, prevent re-introductions
and protect Park resources. This campaign dovetails well with similar partnerships and information
regarding sustained reductions of rats, cats, mongooses and hogs from within NPS lands. In all cases,
efforts in Phase III will increasingly focus on efforts to restrict new animals from entering the Park.

The timeframe for implementing each phase of the sustained reduction program will be: Phase I and
Phase II concurrent for the next one to four years beginning in June 2004; and Phase III will monitor
throughout VINP and accomplish partnership and educational goals. The educational component and
continued partnerships are essential and must be renewed, strengthened and sustained indefinitely. The
ultimate goal of Phase III is to prevent or reduce non-native wildlife encroachment


ENVIRONMENTAL CONSEQUENCES

The potential consequences of implementing "Alternative 2, Reduce Goats and Sheep within VINP and
Sustain a Near-zero Population," are analyzed in the EA; key impacts are summarized below:


Effects to Threatened and Endangered Species

The NPS is required to identify and promote the conservation of all federally listed threatened,
endangered, or candidate species within Park boundaries and their critical habitats. The NPS is also
required to protect all state and locally listed threatened, endangered, rare, declining, sensitive, or
candidate species, provided they are native to and present in the parks, and their critical habitats (NPS
Management Policies 2001).

The sustained reduction program will greatly decrease population levels of two non-native animals, goats
and sheep, which consume numerous plant species living on St. John. The listed species include the
Endangered St. Thomas Lidflower Prickly Ash and Marron Bacora, which has been proposed for listing.
Goats and sheep will also no longer be affecting twenty-five territorially threatened and endangered listed
plant species with extinction within the Park.

The proposed restoration programs will not adversely impact any federally listed threatened or
endangered species or territorially listed endangered or rare species (U.S. Fish and Wildlife Service
Consultation Letter of July 15, 2002)

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Effects to Wildlife


Wildlife will be positively benefited by this program because great numbers of native fauna including
several native bird, reptile and amphibian species and numerous insect and spider species will benefit
from the reduction of goats and sheep populations. The substantial cessation of goat and sheep grazing
and trampling in specific locales, will improve habitat for lizards, snakes, salamanders and insects
dependent upon the consumption of leaves, fruits and berries for their survival; their enhancement should
provide additional food for several native bat species. Goat and sheep removal from riparian areas will
improve riparian habitat for frogs and aquatic invertebrate species dependent upon the consumption of
plants for their survival. Goat and sheep reduction will allow years of higher production of fruits and
berries and will improve habitat for those species which depend upon these crops, such as many bird
species (pigeons and doves) and bats. Of particular concern are the varied native reptile and amphibian
populations in the Park and their associated links in the food and ecological web of the island.


Effects to Wetlands, Saltponds and Floodplains

Wetlands, saltponds and floodplains will positively benefit from implementation of this program because
goat and sheep impacts will decline throughout the Park. Adverse impacts to wetlands will substantially
decrease under this alternative as the native flora and fauna will change under natural conditions.

The decline in the quality of the Park's wetland and floodplain communities will be a reduced concern.
High sedimentation rates with low watershed soil stability due to goat and sheep trampling and grazing
impacts will decrease as the numbers of goats and sheep decrease. Goats and sheep will no longer be
substantially foraging red, black and white mangrove seeds, propagules and seedlings, protected species
in the Virgin Islands. A decrease in goat and sheep grazing and trampling will reduce rates of erosion and
sediment deposition in wetland communities in Cruz Bay, Mary's Creek, Haulover Bay, Newfound Bay,
Hurricane Hole, Coral Harbor, Fish Bay and Hassel Island. Of particular concern are the varied native
reptile and amphibian populations in the Park and their associated links in the food and ecological web of
the island.


Effects to Soils

Within three years of implementation of this alternative, soils in the park will be positively benefited by
the reduction of disturbing activities from goats and sheep. Substantial reductions will eventually allow
disturbed areas to heal over with vegetation. No new goat and sheep trampling and vegetation grazing
areas will be established.

Eventually, erosion from already disturbed sites will decline as the sites establish vegetation cover. As
vegetation cover increases, overall watershed conditions will continue to improve. As watershed
conditions improve, runoff within the watershed will be more readily intercepted by vegetation and be
absorbed on site. This will cause less intense runoff events and decrease the rate of gully erosion
(aggredation and widening). Less intense runoff events will cause less sediment delivery into local
waterways and near shore ocean waters where it can affect coral reef, mangrove, seagrass bed ecosystems
and adjacent fisheries, nurseries and associated marine communities.

The use of existing trails could also lead to a short-term increase in soil erosion. The increase in soil
erosion and the impacts to the soil micro-flora will likely decline once the goats and sheep are reduced

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from the Park and use of the hunting trails is discontinued. These trails will be ephemeral and not heavily
used. Traps will be placed in previously disturbed areas to reduce any potential impacts to soils.

Trampling of the soil by vehicles and the hunters could cause alterations in the soil micro-flora and
cryptobiotic soil crusts may be damaged. Cryptobiotic soils are important components of soils in arid and
semi-arid environments and trampling, especially during the dry season, easily damages these soil crusts.
These soil crusts have the ability to re-colonize disturbed areas from nearby non-disturbed land; however
re-colonization and re-establishment of soil crusts in an area can be somewhat slow depending on various
environmental factors.


Effects of Chemical Immobilization Drugs

A comprehensive long-term control approach must involve flexibility, therefore use of the "Judas" goat
technique may be necessary, and however, the Park only intends limited use of this option. The chance of
using this secondary control technique remains small and would be only considered for goat control.

As described in the Goats and Sheep Implementation Plan in Chapter II, the use of chemical
immobilization drugs is not expected to produce any primary or secondary toxicity impacts to non-target
wildlife. Because goats are highly social animals, an animal equipped with a radio transmitter can lead
field personnel to remote locations where goats congregate (Taylor and Katahira 1988; White and Garrott
1990). This method of locating animal concentrations in steep slopes and dense underbrush can be an
effective means to collect exotic goats. Goats used in this fashion are called Judas goats. Before fitting
an adult goat with a radio transmitter, the animal must first be captured and restrained through injection of
chemical sedatives. The fastest, safest and most humane method to restrain goats for attaching a radio
collar is through chemical restraint. Standard large-animal restraint drugs will be used to temporarily
sedate trapped goats. USDA-APHIS personnel have extensive training in the preparation and use of
chemical restraint and immobilization drugs for large (and small) animals throughout North America
(Kreeger 1997). Their experience includes many successful goat and sheep reduction or eradication
programs.

Telazol is a combination of tiletamine and zolazepam and will be used in conjunction with Rompun to
reduce nausea (Kreeger 1997). Goats are particularly susceptible to overheating and will be kept in the
shade with provisions for wetting them down as necessary (IWVS 1991) Intramuscular Telazol injections
will be administered by either a jab stick, blow gun or C02 pistol to captive individuals in corral or box
traps. Fewer than five goats will be collared in each watershed. Immobilization drugs and drug delivery
equipment will be restricted to employees responsible for goat management under the direct field
supervision of the Program Coordinators. These employees must have completed a Wildlife
Immobilization Practitioner Course as required by NPS-77-4. Immobilization drugs will be stored in a
locked safe and records will be maintained to include the date, amount used, purpose, and authorized
signature of the user. Telazol and Rompun are listed as a Class II substances, therefore, all use and
storage guidelines specified by the Drug Enforcement Administration will be followed (Fowler 1978).
Radio-collared animals will be monitored at least twice a year to detect and remove ingress animals into
the control units (Hegdal and Colvin, 1986; Kreeger 1997). Judas goats will be humanely collected for
removal of radio transmitters following a maximum three-year period.






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Effects to Vegetation


Impacts to native flora will be greatly reduced because fewer goats and sheep will consume less native
vegetation. Goats and sheep are voracious browsers of vegetation and prefer native plants because these
plants evolved in isolation from large herbivores and lack defenses against these ungulates. Fewer seeds
from exotic plant species will be dispersed in goats and sheep fecal matter. Alternative 2 will initially
involve Wildlife Control Agents in an intensive reduction effort. This reduction effort will be expected to
last two to three years. Negative effects to native vegetation and individual plants by wildlife control
agents will be short-term, insubstantial, and ephemeral, if any. Short-term impacts to native vegetation
will occur as goats and sheep are chased and cornered. These impacts will include trampling of the
vegetation, damage to individual plants as leaves, branches and running animals and hunters tears shoots.

Twenty-six long-term ecological monitoring sites (Weaver 1999) could potentially be permanently fenced
to exclude goat and sheep populations. Valuable long-term ecological data will be preserved.
Additionally, even with the current road and trail systems, the teams might create trails as they move
between different areas in the Park. These trails will be ephemeral and not heavily used. These
temporary trails are consistent with park use and management guidance. Impacts associated with the
installation of these trails are minimal compared with goat and sheep impacts to scenic values, cultural
resources, public safety, soils, threatened and endangered species, vegetation, wildlife, water quality and
wetlands. Trails and fencing will avoid any vegetation over one inch DBH and will consist of underbrush
thinning sufficient to permit passage of humans or installation of fences. Vegetation will be allowed to
regrow after fence installation to mitigate potential visual impacts.

Goat and sheep impacts to the native island vegetation, including endemic and Federally and Territorially
listed plant species, will be substantially reduced in Cinnamon, Reef, Leinster, Brown, Francis, Maho,
Lameshur bays, and Lind Point area, and Hassel Island. Plant communities will readily benefit by
seedling survival, increase of cover, frequency, biomass of native plant species, increased topsoil and
water absorption.


Effects to Cultural Resources

Goats and sheep will no longer seriously damage irreplaceable archeological and historical sites, and
degrade the scientific importance of the St. John archeological record. Implementation of this alternative
will result in rapid reduction of goats and sheep and, therefore, reduce continued damage to cultural
resources through goat and sheep depredations on archeological and historical sites at Cinnamon, Reef,
Leinster, Brown, Francis, Maho, Lameshur bays, Lind Point and Hassel Island. Goat and sheep grazing
through disturbance has already adversely affected the integrity of many National Register-listed
archeological sites within VINP.

Impacts to the Park's cultural resources by fencing and direct reduction operations are anticipated to be
insignificant. The primary reduction movement made is_foot traffic, and some may be near archeological
sites. These areas are currently open to the public and risk continued destruction by goats and sheep
unless this alternative is taken. Impacts of this type could be minimized by orienting the reduction groups
to the sensitivity of these sites to damage, and requesting they avoid foottraffic over historic structures
whenever possible. Campsites, fences and installation sites will be assessed in advance using shovel-
testing for cultural resources concerns. Fence posts will require test holes to ensure protection of
archeological resources


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The NPS provided information to the USVI's State Historic Preservation Officer (SHPO), with the
determination that the NPS Preferred Alternative will not cause adverse effects to archaeological and
cultural resources including submerged resources or historic structures. Since no objection was received
from the SHPO, pursuant to 36 CFR 800 of the National Historic Preservation Act, Section 106
compliance has been completed.


Effects to Socio-economic

The proposed action to conduct Park-wide reduction of non-native goats and sheep will have some short-
term negative impacts on socioeconomic issues but will also have long-term positive impacts on the
quality of the visitor experience. The long-term positive effects greatly outweigh the short-term effects.
Goat and sheep ranchers will discontinue their use of Park lands for livestock grazing, and the associated
negative affects of the practice. The ranchers will be able to maintain their entire herds, for the
production of milk, meat and wool, on their private livestock ranches. Visitor use will be restricted on
those specific NPS lands when major collection operations occur. Fences will be located to avoid
crossing roads. Gates, which may potentially affect resident or visitor movements, will not be installed.

Park-wide reduction will be an intense effort over a short period of 3 to 4 years. Depending on the
planned operation in the initial three years of intensive reduction effort, relatively small portions of VINP
could be closed for brief (for example, two consecutive days) periods of time. Visitor use will possibly be
slightly restricted on various portions of Federal lands during goats and sheep reduction operations.

Over the last ten years, the annual visitation to St. John Island has averaged approximately one million
visitors per year. However, some visitors will possibly be denied access to various public trails due to the
presence of aggressive goats and sheep. Goat and sheep reduction personnel will contribute financially to
the local economy through purchases of goods and services, vehicle rental and equipment purchases.


Effects to Visitor Experience

The NPS will receive fewer complaints from visitors about goats and sheep and their impacts to the Park.
Scenic values will increase under this alternative because goats and sheep will no longer be eating,
trampling, crushing and uprooting native flora the public hopes to observe and expects to have preserved.
The aesthetics of the Park will be greatly increased due to the increase of native wildlife, increase of
native plant cover, and increase protection of archeological and historic sites. The natural and cultural
values of the Park will greatly increase. Therefore, the reduction of goat and sheep depredations on Park
sites will also reduce damage to natural, cultural, marine and terrestrial resources throughout the Park.

Goats and sheep will be less dangerous to people in certain situations. Goats and sheep will be less likely
to cause resident, visitor or employee traffic accidents or congestion while driving Park roads. Park trails
will also be safer due to lack of goat and sheep erosional damage to the tread surface caused by goat and
sheep grazing and trampling in the areas immediately uphill of the trail corridor. Road closures will be
less likely following traffic accidents between goats and vehicles or motorists driving off the road to
avoid collisions with goats or sheep. The tourist experience at VINP will be substantially improved.

Health and sanitation impacts will necessarily improve under this action and sheep and primarily goats
will be less likely to serve as co-hosts with native wildlife and livestock for infectious and parasitic


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diseases. Fecal pellets on and near NPS picnic tables will dramatically decrease, enhancing public
sanitation, disease transmission, and aesthetics.


Effects to Park Operations

The non-native wildlife control program administrative costs will increase with the implementation of the
initial contract to remove exotic wildlife ($60,000 with the USDA's Animal Plant Health Inspection
Service / Wildlife Services Division). Implementation of this alternative will have a low potential for
adverse operational effects because goat and sheep populations will be greatly reduced, and held to low
levels, throughout the Park at all visitor use, administrative, cultural and natural resource sites.

This program will necessitate a slight increase in on-Park personnel, jeep or truck style vehicles and all-
terrain vehicles. Other methods of transportation may also be used, such as horses. Housing will utilize
existing structures whenever possible, including government approved facilities on NPS owned property.
Temporary tent camps may also need to be established to ensure efficient and productive operations in
remote areas, such as boat-only accessible anchorages and rough, roadless terrain. These camps will be
located in areas already affected by vegetation clearing associated with construction of historic buildings
sites located in the Park's backcountry. Two to three miles of fences may be constructed to prevent goat
and sheep access through key portions of the Park boundary.


WHY THE PREFERRED ALTERNATIVE WILL NOT HAVE A SIGNIFICANT
EFFECT ON THE HUMAN ENVIRONMENT


As defined in 40 CFR 1508.27, significance is determined by examining the following criteria:

Impacts that may be both beneficial and adverse
There will be no adverse impacts for visitor safety, as wildlife reduction personnel would operate in
remote field locations most of the time, which are not frequented by the vast majority of VINP visitors.
Positive impacts include reduction of impacts to native vegetation communities and the diverse wildlife
living within the forests, enhanced wetland areas, and retention of soil stability resulting in less
sedimentation and nutrients into adjacent coral reefs. Historical buildings would not be destabilized by
goat herds, enhancing public safety and sanitation. Finally, park aesthetics and visitor experience would
be greatly enhanced overall as the cumulative result of this alternative.

Degree of effect on public health or safety
Use of firearms presents the greatest potential danger to public safety. Live capture methods would
prevail over shooting methods, however, some animals must be shot while inside the trap. The chance of
incidental bullet strikes is basically nonexistent in this situation. A small number of animals may require
shooting while not inside a trap. In this case wildlife reduction personnel would exercise extreme caution
while ensuring a line-of-site with a physical embankment (such as a steep hillside), beyond the target
animal. Most envisioned scenarios would be small-scale events in extremely remote locations. If large-
scale efforts were planned, then close cooperation with NPS and Territorial Law Enforcement personnel
would occur.




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Unique characteristics of the geographic area such as proximity to historic or cultural resources, park
lands, prime farmlands, wetlands, wild and scenic rivers, or ecologically critical areas
While goats and sheep occur within close proximity to historic structures and sensitive wetland (saltpond)
areas, reduction efforts will not generally be conducted in the immediate vicinity of these resources.

Degree to which effects on the quality of the human environment are likely to be highly controversial
Initially wildlife reduction coordinators would work closely with the Territorial Government through the
MOU to humanely remove animals from the park. From public meetings that were conducted, the park
learned that local wildlife ranchers do not intentionally keep their goats and sheep on NPS lands. The
prevailing attitude is entirely supportive of this program; therefore, no controversy is anticipated upon its
implementation. Community support is overwhelmingly supportive of this wildlife reduction action,
associated methodology and final disposition of collected animals.

Degree to which the possible effects on the quality of the human environment are highly uncertain or
involve unique or unknown risks
Because VINP has undertaken wildlife reduction projects with rats, cats, mongooses and hogs, the park
has an accurate basis for predicting possible effects on the quality of the human environment. Therefore
predictions are made with a high degree of certainty the effects of this action would be entirely favorable
to island residents and visitors. The extremely low risk level anticipated from the use of some wildlife
control methods being considered can be essentially eliminated as a result of proper planning,
communication and implementation.

Degree to which the action may establish a precedent for future actions with significant effects or
represents a decision in principle about a future consideration
This action is entirely consistent with existing Federal and territorial laws and regulations and represents a
continuation and strengthening resolve to humanely remove introduced mammals from VINP. This
action affirms the park's status as an International Biosphere Reserve to administer established principles
of conservation biology. This project continues the effort to protect native flora, fauna, wetland and
adjacent marine resources for the enjoyment of future generations.

Whether the action is related to other actions with individually insignificant but cumulatively
significant impacts
None of the anticipated impacts from this or related actions can be considered as individually
insignificant but cumulatively significant. Neither individual nor cumulative impacts are
significantly negative for residents, visitors or resources.

Degree to which the action may adversely affect districts, sites, highways, structures, or objects listed
on National Register of Historic Places or may cause loss or destruction of significant scientific,
cultural, or historical resources.
The impacts from the proposed action would not adversely affect districts, highways, structures or objects
listed on the National Register of Historic Places, or cause loss or destruction of significant scientific,
cultural, or historical resources. However, each of these items would continue to be adversely affected, to
an increasingly greater degree, unless this action is taken.

Degree to which the action may adversely affect an endangered or threatened species or its critical
habitat
The anticipated impacts would not adversely affect an endangered or threatened species or its critical
habitat. The action is anticipated to reduce grazing threats to two endangered plant species.


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Whether the action threatens a violation of Federal, state, or local environmental protection law
This action violates no Federal, state or local environmental protection laws.


NON-IMPAIRMENT OF PARK RESOURCES

After a critical review of the environmental impacts documented in the EA, the NPS Preferred and the
Environmentally Preferable Alternative has been selected for implementation. This alternative, together
with the recommended mitigation measures will not impair Park resources or values, including the current
opportunities for the enjoyment of these resources or values. Implementing the Selected Alternative will
not violate the NPS Organic Act.


FINDING OF NO SIGNIFICANT IMPACT

Based upon the EA, the consequences of the Environmentally Preferable Alternative summarized above,
and comments from agencies and the public, I have determined Alternative 2 will not have significant
effects on the quality of the human environment. Therefore, in accordance with the National
Environmental Policy Act of 1969 and regulations of the Council on Environmental Quality (40 CFR
1508.9), an environmental impact statement will not be prepared.

Factors considered in making this finding include:

* The impacts resulting from the sustained reduction program will not impair any Park resources or
value necessary to fulfill specific purposes identified in the park's enabling legislation. The program
will not violate the NPS Organic Act.

No threatened or endangered species or critical habitats are likely to be adversely affected. (July 15,
2002 letter from U.S. Fish and Wildlife).

* The NPS provided information to the Territorial Government, State Historic Preservation Officer
(SHPO), with the determination the NPS Preferred Alternative will not cause adverse effects to
archaeological and cultural resources, including submerged resources or historic structures. Since no
objection was received from the SHPO, pursuant to 36 CFR 800 of the National Historic Preservation
Act, Section 106 compliance has been completed.

The activities to be implemented by the Plan are consistent with the Coastal Zone Management Act
and with the Coastal Zone Management Plan. The NPS provided information to the Territorial
Government Department of Planning and Natural Resources with the determination the NPS
Preferred Alternative is consistent with the Coastal Zone Management Act, under the Territorial
Government of the USVI.

The activities authorized by the Plan are consistent with NPS Management Policies and Natural
Resources Management Guidelines, the General Management Plan (NPS 1983) and Resources
Management Plan (NPS 1999) for the Virgin Islands National Park, applicable Federal and
Territorial laws and regulations, and complies with Executive Orders 11988 and 11990.




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* The authorized activities for reducing non-native wildlife populations will not have a significant
impact on public health and safety or on consumers, minority groups, American Indians, women, or
the civil rights of any person.

* This program is not a unique activity and the effects on the quality of the human environment are not
likely to be highly controversial, nor are they highly uncertain or involve unique or unknown risks.


Recommended: Art Frederick
Superintendent, Virgin Islands National Park


Approved: Patricia A. Hooks
Regional Director


7/13/04
Date


7/29/04
Date


DECISION NOTICE AND FONSI
SUSTAINED REDUCTION PLAN FOR NON-NATIVE GOATS AND SHEEP
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ERRATA SHEET
SUSTAINED REDUCTION PLAN FOR NON-NATIVE GOATS AND SHEEP
WITHIN VIRGIN ISLANDS NATIONAL PARK
Virgin Islands National Park

COMMENTS AND RESPONSES

Two written comments were submitted during the 60-day public comment period on the Draft EA for a
Sustained Reduction Plan for Non-native Goats and Sheep within Virgin Islands National Park. Issues
raised include: general comments of support; use of fertility control methods; boundary fence installation
and maintenance by private livestock owners; the mosaic of Park and private lands; use of dogs to locate
animals; use of live traps preferentially over kill traps; use of leg snares to trap animals; how collected
animals will actually be euthanized, use of volunteers to prevent new wildlife introductions, a suggested
alternative, to remove goats to a United States wildlife sanctuary. The single modification to the Final
EA was in our clarification of snare usage, and the scope remains unchanged. Otherwise slight changes
either clarified the text or were grammatical. The responses below were largely copied from the Draft EA
text and were strengthened for clarification.

1. General Comments of Support from The Humane Society of the United States

Comment: Ecosystems are not static, unchanging systems; they are constantly in a state of flux. Species
introductions and range expansions can be a natural phenomenon and can occur with and without human
intervention. With this in mind, we suggest that, before any attempt to eradicate or control a non-native
species is undertaken, scientific evidence must clearly indicate that the non-native species in question is
actually damaging native species and ecosystems and that removal of the non-native species will actually
benefit native ecosystems. Not all non-native species are actually "invasive" in the sense of causing harm
to the long-term viability of native populations. The benefit to native species of non-native species
removal is often taken as a given, but such a benefit may not occur, especially in systems in which the
non-native species has become firmly established, where native ecosystems have already been
irreversibly impacted, and where removal efforts may essentially cause more harm than good.

In addition, the humaneness of potential control methods-both for target and non-target species-must
be taken into account. Scientific research can be used to determine whether reproductive control or other
non-lethal methods can be substituted for lethal control and to assess which lethal control methods will
minimize pain and distress. Humaneness of control efforts will also be impacted by the duration over
which control is carried out; if it is not possible to completely remove all non-native animals from an
area, plans for eradication often become ongoing lethal control activities with no end in sight.

With that said, we understand the impact that introduced species can have on native species and that the
impact to threatened or endangered species endemic to an island may be substantial. Island systems may
represent the best, or perhaps only, systems in which attempted removal of non-native species may be
both justified and feasible. We are concerned that in Virgin Islands National Park (VINP), the presence
of numerous private inholdings within the Park, as well as more private property immediately adjacent to
the Park, will present special problems to the Proposed Alternative of the EA that could impact the
welfare of the target sheep and goats, as well as non-target animals, in part due to the likely duration of
lethal control activities. We address this and other concerns briefly below.




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Response: The NPS has not modified the Goats and Sheep Implementation Plan in Chapter II of the
Final EA to address these concerns by The Humane Society of the United States.


2. Potential Use of Fertility Control Methods

Comment: We note that the EA analyzes only two alternatives, a No Action Alternative and the
Proposed Alternative, whereas the National Environmental Policy Act requires consideration of a
reasonable range of alternatives. We encourage the National Park Service (NPS) to provide more
information in the Final EA regarding the potential use of fertility control methods with goats and sheep
within VINP. In particular, the Final EA should provide more information regarding the likely ecological
impacts of sheep and goats over time if populations of these animals were reduced slowly via fertility
control, rather than more rapidly by lethal control. We understand that a contraception project was at
least initiated to address the feral donkey population in VINP;1 the NPS should indicate why similar
projects are not being considered for sheep and goats within VINP. Fertility control is considered by
some to be more humane than some of the control strategies included in the Draft EA, such as snares and
shooting. If this method could check sheep and/or goat populations sufficiently to protect native
ecosystems from further significant damage, then it may be an appropriate management tool in this
situation. If fertility control is a feasible alternative to lethal control for goats, or at least for the far less
numerous sheep, then we encourage the NPS to give full consideration in the Final EA to an alternative
that will incorporate fertility control of one or both species as a management strategy.

Response: Page 29 of the EA discusses Use of Contraceptives or Sterilization, an Alternative Considered
but Eliminated from Detailed Analysis. Contraception or sterilization could be a relatively benign way to
prevent the birth of new goats and sheep in an area; however, the original animals will remain in the area
unless they are humanely removed.

A research project was initiated in 1991 solely to test the efficacy of Porcine Zona Pellucida (PZP) on
non-native donkeys. PZP is not recommended as a population control method but is suitable for
preventing pregnancy and subsequently limiting birth rates in the short run. Because immune -
contraceptives were developed in the temperate region where ungulates breed seasonally, their
effectiveness is amplified. Subtropical populations breed seasonally making contraceptives less reliable.
Because males remain fertile, almost 90 percent of the females require sustained contraception to reduce
the birth rate.

Unfortunately, birth control technology is presently inadequate to achieve a substantial, immediate and
cost-effective reduction of goat and sheep populations throughout the Park. This is especially true when
goat and sheep herds are thriving throughout the Park, which is entirely covered with vegetation and has a
year-round growing season. Contraceptives are expensive and require annual reapplication for each
treated individual, thus necessitating the ability to humanely and semi-permanently mark and re-identify
individual females. Contraception is impractical, expensive and ineffective for our mandates to humanely
reduce goat and sheep populations throughout NPS lands to near-zero limits. For these reasons use of
contraceptives or sterilization were considered alternatives but were rejected from detailed analysis during
the planning process.






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3. Boundary Fence Installation and Maintenance by Private Livestock Owners

Comment: We appreciate the attention in the EA to the need for fencing and for education of private
livestock owners to address the repeated ingress of sheep, goats, hogs, and other non-native feral animals
into VINP. In particular, we support the provision allowing sheep and goat owners 60 days to remove
their own animals from within the Park before the actions outlined in the Proposed Alternative are begun.
Based on a phone conversation with R. Boulon (2/12/04), it is our understanding that any ear-tagged
sheep and goats captured after the 60 days and at any time during the implementation of the Proposed
Alternative will also be returned to their owners. We agree with this reasonable provision. Although we
are not familiar with the Animal Registration and Impoundment Program, some way to ensure that all
privately owned sheep and goats are ear-tagged or otherwise uniquely marked at or soon after birth will
be necessary to ensure that goats and sheep entering the Park in the future can be returned to their owners,
who can then be held accountable for the escape or release of their animals.

We support the use of fencing to protect vegetation monitoring plots and along selected stretches of the
VINP boundary. We also support an aggressive outreach and education campaign to reduce further sheep
and goat introductions to the Park, as well as any efforts to assist private landowners with fence
installation and repair to prevent further ingress of privately owned sheep and goats onto Park lands.

Addressing the source of sheep and goat introductions via education, outreach, and exclusion or barrier
fencing will be absolutely crucial considering the repeated releases, escapes, and abandoning of domestic
sheep and goats from private lands in and near the Park. If Volunteers-In-Parks will be asked to assist in
the removal of sheep and goats, these volunteers could also be asked to assist with the installation and
maintenance of fencing to help prevent further introductions of sheep and goats (reducing the need for
future removals) and to help protect vegetation monitoring plots or any especially sensitive areas within
the Park. We suggest that the Final EA incorporate the use of local volunteers to help prevent further
introductions of sheep and goats (by assisting with fencing) rather than simply to help remove the sheep
and goats that have already made their way into the Park.

Response. Ungulate-proof fences will be considered for installation to permanently restrict their access to
park land immediately adjacent to Herman Farm, L' Esperance and Catherineberg, and within portions of
Brown, Reef, Lameshur, Cinnamon, Hawksnest and Francis bays, the NPS Range, Ram Head and Hassel
Island. These locations have been historically breached by goats or sheep, and allow easy entry into
VINP. Where necessary, restricted-access, ungulate-proof gates will be installed and maintained; these
gates will not change human access to park lands. During fence installation the opportunity will be used
to collect subsurface archeological information on a systematic basis by mapping and shovel-testing the
post holes as they are dug. NPS may provide funds to assist ranchers with fence installation or repair
fences on their wildlife ranches to reduce non-native animal encroachment into adjacent or nearby NPS
lands.

Chapter II includes: "Fence installation will follow consultation with ranchers, and VIDA. Their
assistance and cooperation will be solicited and encouraged throughout the ongoing goat and sheep
reduction program. Enhanced community outreach through numerous governmental and non-
governmental organizations will continue to be an essential and ongoing component, as well."

The siting, clearance, installation and maintenance of ungulate-proof fences in the subtropics are a
serious, expensive, and arguably ineffective method. Pages 27 to 29 of the EA thoroughly discuss the use
of fences and much is applicable to fencing research plots and portions of the boundary. Of paramount
importance is establishing and maintaining a partnership between St John wildlife ranchers and the groups

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which are working together to humanely remove goats and sheep from park lands. This ongoing
partnership would ensure ranchers understand the impacts their livestock make to the park, and allow
assistance from resource managers. In this effort NPS can possibly provide funding to ensure the private
ranch fences are adequate. Only wildlife ranches fully compliant with the VIDA Animal Registration and
Impoundment Program will qualify to receive goats and sheep captured from within VINP.

The NPS is reluctant to establish large-scale fencing within the Park because they are extremely
expensive to install and maintain and become ineffective over time. Selective boundary and research plot
fencing were noted as an option for future consideration. If and when any additional fencing is
conducted, every effort will be made to solicit for VIP's to both install and maintain them for the purpose
of preventing future goat and sheep encroachments.

The Volunteers-In Parks (VIP) program will possibly be used to involve a limited number of residents to
share their knowledge and hunting skills and labor to assist with specific goat and sheep collection
activities. Local knowledge will be gathered from island residents regarding trap design, manufacture and
placement, seasonality, timing and bait choice. This program responds to a cultural tradition and includes
a long history of goats and sheep on the island, and archaeological information regarding enslaved
African Americans, and others, supplementing their diets (at least in some areas of the Americas) through
hunting, fishing, and trapping (Olwig 1985). NPS volunteers (Volunteer-in Parks) will be solicited to
assist with both the installation and maintenance of NPS boundary and research exclosure fences to help
prevent further introductions of goats and sheep.

VIP's authorized by VINP will participate under the exclusive direction and authority of the Park
Superintendent (or his designee); such VIP's will be prohibited from using firearms and must participate
within the strict guidelines established by the NPS and USDA Program Coordinators.


4. The Mosaic of Park and Private Lands

Comment: The mosaic of Park and private lands will make it difficult to completely prevent further
introductions of sheep and goats and will make it difficult, if not impossible, to remove all sheep and
goats from VINP. Thus, if the NPS moves forward with the Proposed Alternative, some level of lethal
control of sheep and goats is likely to continue for several years. Due to the likelihood of long-term sheep
and goat control within VINP, full consideration of the humaneness of control methods-and the
potential to substitute fertility control for lethal control-is especially important.

Response: Approximately 52.0% of the island is Federal land. The Park owns 2,816 hectares (7,444
acres) of the 3840 hectares (9,485 acres) authorized by the enabling legislation. Within the Park
boundary, 26.5% (901 hectares or 2,226 acres) of the land is owned by either private interests or the
Virgin Islands government. These separate parcels of non-federal land or inholdingss" are dispersed
throughout the federal land within the authorized boundaries. The trend has been to further sub-divide the
parcels and develop them. There were 261 parcels of non-federal land in 1991 and approximately 322 in
1992.

The NPS is unable to restrict development on private adjacent lands, as our Enabling legislation lacks
eminent domain authority. Local zoning or Coastal Zone Management Act (CZM) protection is often
inadequate due to relaxed or inconsistent enforcement. Virgin Islands National Park participates in CZM
on any permit review for construction or modification of land within or adjacent to Park boundaries and
offers comments. The Resource Management Division has established mechanisms for the Park to be

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contacted on adjacent development issues and to participate in the review/permitting process. There is
also a need to upgrade the Park's land status maps (1986) to show changes in ownership and anticipate
potential development. Due to lack of eminent domain authority, the Park has to compete for NPS
acquisition funds and must work closely with groups like the Friends of Virgin Islands National Park and
Trust for Public Lands. These non-profit NGO's can either purchase or hold land until Park funds are
available or purchase and donate land to the Park.

Because eradication is unfeasible, our goal is to humanely reduce goat and sheep populations and keep
them low. A vast majority of animals are expected to be relocated to wildlife ranches. At those locations
the goats and sheep will generally be utilized for consumption; the primary reason livestock producers
keep goats and sheep. Some goats and sheep might be killed instead of expensively captured and
harvested later on a wildlife ranch. Additionally, to live-capture and transport goats and sheep over a few
miles of rough trails, then by boat or trailer into a wildlife ranch, NPS would consider inhumane.

Development of private inholdings within and adjacent to the Park boundary, and pressure to re-open or
pave old Danish cart roads within the Park, represents serious threats to marine and terrestrial ecosystems
in the Park. Clearing of St. John's steep hillsides on slopes, 80 percent of which exceeds 30 degrees, has
resulted in threats to native species, spread of exotic plants, increased soil erosion, loss of sparse topsoil,
and fragmentation of the forest and "viewsheds". These impacts need to be minimized or at least
mitigated. Because development cannot be prevented, eco-sensitive development must be encouraged to
require use of recycled and low energy products as well as forested scenic easements. Agreements with
landowners could be developed to achieve energy savings, and to minimize loss of biological diversity,
introduction and spread of exotic species, degradation of Park resources and scenic values.

We considered all pertinent factors including economic, logistic, financial, and health and safety of
livestock, wildlife workers, island residents and visitors. The approach to use fertility control
methodology was considered, analyzed and rejected as a viable option and was fully addressed in a
previous response. Additionally, to fence (and gate) the entire park and remove goats and sheep by zone-
fenced hunting was also considered and rejected as unfeasible, unrealistic and impractical. One must
remain cognizant to consider some lethal methodology, to control animals raised almost exclusively for
slaughter and consumption, and animal husbandry practice. To deny this established and widely accepted
practice is perhaps disingenuous.


5. Use of Dogs to Locate Animals

Comment: We always have concerns over the use of dogs in tracking or removing wildlife or feral
domestic animals due to the potential for injury to the dogs and to the targeted animals. Therefore, we
appreciate the assurance in the EA that only baying dogs-not catch dogs-will be used, that dogs will be
under control at all times, and that dogs will not be allowed to contact sheep or goats (EA, p. 23).
However, the potential will always exist for dogs to inadvertently come into contact with sheep, goats, or
other animals that may be encountered in the field. We also appreciate the assurance that dogs will only
be used when other methods have been attempted and have failed to remove the last sheep or goat in an
area.

Response: Use of well-trained and experienced tracking dogs can be extremely cost effective when
seeking to remove a small number of remaining, trap-shy individuals. Use of dogs will be considered for
humanely collecting individuals where other alternatives have failed. The removal of every possible goat
and sheep from remote densely vegetated locations will possibly require the use of trained tracking dogs.

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These specialized animals will be brought in from the U.S. mainland and maintained under strict control
at all times. Dogs will be under the control and guidance of USDA Program Coordinators and visitor
safety will be foremost in all wildlife operations.

Chapter II includes: "Every successful NPS goat and sheep reduction program on an island or on a
mainland environment has relied upon the use of tracking dogs to locate the last remaining goats and
sheep. Tracking dogs are being used at Hawaii Volcanoes and Channel Islands National Parks to locate
goats in steep terrain, and in dense brush and forest. Only if a decision or the opportunity to capture the
"last goat" is made will VIIS use tracking ("baying") dogs, and only under the guidelines stated above.
They will only be used to locate goats and not contact the goats. As they will be under strict control at all
times, they will produce no impacts to ground-nesting birds. Dogs, prior to being allowed in the Park,
will be vaccinated for all common canine diseases. The USDA will be required to submit inoculation
documentation. The safety and well-being of the dogs and wildlife reduction personnel will also be of
importance."


6. Use of Live Traps Preferentially over Kill Traps

Comment: We appreciate the assurance in the EA that live-traps will be used preferentially over kill
traps (EA, p. 21) and that neck snares "will only be considered for deployment under rare circumstances
and in remote locations (EA, p. 22)." However, the definition of "live trap" and "kill trap" is unclear in
the EA. We assume that, by "kill traps" the NPS is referring specifically to neck snares, whereas by "live
traps" the NPS is referring to single box and multiple corral-style live traps and leg snares (EA, pp. 21 -
22 and elsewhere). Statements on p. 24 suggest that the NPS considers neck snares to be live traps,
though it is not clear in that instance what is meant by "kill traps." If the NPS is considering the use of
some other type of kill trap (other than the neck snare), this must be clarified in the Final EA. Regardless,
we object to any use of neck snares in this project, whether they are supposed to function as live traps or
as kill traps. We acknowledge that the neck snare may simply hold an animal, or may result in a relatively
rapid death, but we are not convinced that either of these outcomes will be more likely than the slow,
potentially painful death that has been documented for some species, such as foxes and coyotes. The EA
indicates (without reference to any published work) that most animals found in neck snares are found
alive, but also suggests (again with no support) that deer caught in neck snares tend to struggle to such an
extent that they die a rapid death by strangulation (EA, p. 22). These two statements appear
contradictory. In addition, we are not certain what duration of time the NPS considers "rapid." If the
NPS insists on the use of neck snares, despite the potential for these traps to cause unnecessary
pain and distress, the Final EA must provide more information, based on peer-reviewed research,
regarding the use of neck snares with ungulates. Specifically, the Final EA should indicate the
likelihood that the neck snare design to be used by the Park-whether a "regular" wire snare, power
snare, snare with "stops," or snare without stops-will function as a kill trap (including the average
duration of time to loss of consciousness of snared ungulates), as well as the likelihood that the neck snare
will hold goats and sheep without killing them or causing injury. This additional information will allow
the public to make a more informed decision regarding the need for the use of this type of trap.

Response: Use of snares for lethal capture may be necessary in extremely remote areas at some future
time. Use of hold snares such as plastic or rubber-coated snares with stops are considered more inhumane
than standard neck snares. Wildlife in hold traps often suffocate over a period of hours rather than
minutes, as with standard snares. While some practitioners consider hold traps more humane, in part
because they are size and species specific, we believe ungulates expire more quickly and humanely
without stops. Use of lethal snares will be minimal, if any, and in extremely limited situations when other

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capture methodology have failed. Due to the topography, vegetation and few trees, the EA must be
realistic, comprehensive and flexible in methodology. This requires a range of reduction techniques to
safely and humanely satisfy NPS mandates.


7. Use of Leg Snares to Trap Animals

Comment: The HSUS also has serious concerns over the humaneness of leg snares. Among coyotes
trapped in leg snares for no more than 24 hours, 25% and 80% of coyotes trapped in Fremont and Novak
snares, respectively, exhibited maceration of soft tissue; 50% of those trapped in the Novak snare had
limb fractures; and edematous swelling and/or hemorrhage occurred in coyote limbs trapped by either the
Fremont or Novak snare. The only information in this study pertaining to ungulates is provided on non-
target deer that were caught in one type of snare: "All 5 deer caught were taken in Fremont snares. These
animals seemed to struggle a great deal, as evidenced by muscle bruising in all 5, and dislocation of the
fetlock joint in 1." Sheep and goats will be similarly likely to struggle in leg snares. Therefore, we
strongly urge the NPS not to use leg snares. At minimum, the Final EA must indicate whether snares
designed to minimize injury-e.g. leg snares coated with plastic-will be used. Whether such
modifications actually benefit the welfare of a given species may be debatable, but certainly the Final EA
should address the ways in which the NPS will seek to minimize the injuries, pain, and distress produced
by this and other methods of control.

One clear method of reducing pain and distress of trapped animals is the use of a short trap-check time
and we appreciate the provision in the EA that all traps and snares will be checked at "maximum 12-hour
intervals (EA, p.22)." While more frequent monitoring of traps and snares-such as every 2 6 hours-
will certainly be preferable from an animal welfare standpoint, 12 hours is a reasonable maximum.
However, there appears to be a typo on p. 22, which indicates that guidelines for trapping goats and sheep
include trap inspection "within 12 hours minimum" rather than a maximum of 12 hours. The Final EA
must clarify that traps and snares will not be left unattended for more than 12 hours.

Response: The NPS has modified the Goats and Sheep Implementation Plan in Chapter II on Page 22 of
the Final EA to clarify intentions regarding the use of neck snares to trap animals. Live traps are the
preferred method of capture; leg snares will not be used, neck snares may be employed in conjunction
with independent bait stations. Traps and snares will be inspected at maximum 12-hour intervals; often
trap inspections will be every 6 hours or more frequently. Initial trapping typically yield the highest ratio
of animals collected over time, a period days or weeks, and this drops over time until trapping effort in
the area is no longer cost effective.

Neck snares will only be considered for deployment under rare circumstances and in remote locations.
Neck snares will be constructed using slip-wire and secured close to the ground along established
corridors frequented by goats and remote from human activity. Wildlife conservationists consider these
to be live traps for virtually all targeted wildlife captured.

The Draft EA did not specify the precise snare type for possible use. Because HSUS mentions snare use
with stops or plastic or rubber coating, we categorically reject these materials and styles. It was
determined that the use of snares with stops, and use of plastic or rubber-coated snares would be
inappropriate. When snares or captive traps are used, a potential for injury, up to and including death
remains a possibility. A combination of approaches to methodology is necessary to adequately represent
the range of situations wildlife reduction experts will face. This comprehensive approach is favorable to
one employing a single method over a wide range of locations and diverse habitats. The humane

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treatment of wildlife, including those selected for overland transport, is of paramount importance. Many
live-captured animals will later become euthanized and utilized at wildlife ranches. Some will be
euthanized remotely, and donated for utilization.

The live-capture and snare techniques proposed in this program are relatively species specific. These
methods are more expensive to obtain and use, but are preferred over leg snares or kill traps, because they
are more humane when used properly. Possible nontarget (incidental) wildlife includes the following
non-native species: white-tailed deer and donkeys. These two exotic species have been selected for
extensive population reduction programs, albeit their NEPA compliance documentation has not begun.
Nevertheless, few if any of these species are expected to be found in the traps or snares if these methods
were employed. Capture of burros will be extremely rare and those will be released. Other non-native
species will be humanely collected. Again, the humane treatment of all island wildlife is of paramount
importance, and a comprehensive methodological approach is favored as the most humane, safe and
efficient means to accomplish NPS management objectives.

Chapter II includes: "Both target and non-target species are generally found uninjured or only moderately
injured in the snare. A minor amount of injury or trauma is impossible to avoid, while every reasonable
measure will be employed to reduce injury and suffering of both target and incidental wildlife captured
throughout the reduction program."

Initially, traps represent the highest number of animals collected for the least amount of human effort.
Therefore, a few different models or techniques will be employed to collect goats and sheep; including
single and multiple (corrals) live traps. Selective neck snares may be considered as a secondary control
alternative in remote habitats where other primary collection methods have failed. Trap success is a
function of natural food availability, environmental conditions, goats and sheep densities and distribution,
trap placement, trap design, age and previous trapping activity (Fox and Pelton 1977). Portable, chain-
link single-catch traps have been the most practical and efficient traps for capturing goats and sheep in
many areas. These may be constructed for remote use in this program, in addition to the multiple-catch
corral trap envisioned to capture the majority of trapped goats and sheep in this program. Live-capture
traps may be assembled in the field and dismantled for movement to a new site. While live capture traps
are more expensive to obtain and use, they are preferred over kill traps.

Rigid, heavy gauge welded wire panels measuring 4 x 8 feet will be wired together and fastened to an
independent, one-way door. Three panels form a triangular corral trap capable of holding several
animals. Additional panels may be joined to increase the corral size. Pre-baiting with no door may be
necessary.

Although trapping is an effective method of control and can account for the majority of goats and sheep
removed from a Park, it has some limitations. For example, some animals may be "trap shy" and may not
enter traps regardless of bait type or trap location. In addition, it is difficult or entirely unfeasible to
transport traps to some areas of the Park, due to the remote and rugged terrain or without causing serious
impacts to designated natural areas. Finally, in terms of human-hours, trapping is extremely labor-
intensive. Therefore, the most cost-effective long-term method for controlling goats and sheep in the
Park is a combination of trapping and shooting.

Live traps and snares may be used in conjunction with as well as independent of bait stations. Traps and
snares will be inspected at maximum 12-hour intervals. Initial trapping typically yield the highest ratio of
animals collected over time and this value drops over time until the program is no longer cost effective.


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If used, snares will be constructed using slip-wire and secured close to the ground along established
corridors frequented by goats and sheep and remote from human activity. Wildlife conservationists
consider these to be live traps for virtually all targeted wildlife captured. However, white-tailed deer
sometimes behave erratically and may readily suffocate and quickly (and humanely) die. Capture and
disposition of nontarget wildlife is addressed in a separate section immediately above. Again, efforts
throughout all three-program phases will focus on preventing (minimizing) non-native animals from
encroachment to VINP. This is of particular importance during the indefinite time frame of Phase III.


8. How Collected Animals will be Euthanized

Comment: The EA is not clear on the manner in which collected animals will actually be killed. Though
some mention is made of sending some trapped animals to a slaughterhouse, and it is clear that some
individuals will be shot (i.e. those not caught in traps), it is not clear whether all live-trapped or snared
sheep and goats will be sent to a slaughterhouse (or to their owners if ear-tagged), or whether some will
be shot or otherwise killed in the field (in the location in which they are trapped). In a phone
conversation, R. Boulon (12/12/04) indicated that all live-trapped animals will be either returned to their
owners (if ear-tagged) or transported alive to a slaughterhouse. However, the EA (p. 22) indicates that, in
addition to killing goats and sheep via shooting (without trapping), "a silenced pistol will be employed to
safely dispatch some corralled animals." The Final EA should clarify whether any uninjured live-trapped
animals will be killed in the field by shooting or other means. If uninjured live-trapped animals will be
killed via shooting-rather than killed via chemical euthanasia, transported to the owner (if ear-tagged),
or transported to a slaughterhouse-this decision must be justified in the Final EA. The Final EA should
estimate (possibly based on reduction programs in other Parks) the percentage of animals that will likely
be shot in the field (by Virgin Islands Department of Agriculture, the U.S. Department of Agriculture,
NPS, or Virgin Islands Department of Natural Resources officials), transported alive to their owners (if
ear-tagged), transported alive to a slaughterhouse, or killed by other means. The means of transportation
must also be specified. The Final EA must also specify whether trapped and transported animals will be
without water and/or food for any period of time.

Response: Trained and certified animal control agents will collect goats and sheep on the ground or from
temporary tree stands, with the possible use of the techniques and technologies described in the Draft EA.
USDA APHIS and NPS personnel will be qualified and certified for the centerfire rifle or shotgun used to
dispatch goats and sheep, a silenced pistol may be employed to safely dispatch some corralled animals.
Firearms used for this program will be equipped with telescopic scopes and silenced muzzles (except the
shotgun). Transportation of field personnel may include trucks, jeeps, horses, all terrain vehicles and
boats. Temporary tent camps may be established in remote areas.

Again, because eradication is unfeasible, our goal is to humanely reduce goat and sheep populations
within the park and keep them low. A comprehensive and multifaceted methodology must be analyzed
and implemented to ensure success and accomplishment of NPS management directives. Extensive
vegetation cover and steep and largely inaccessible terrain, results in an expensive and challenging
operation to reduce populations of destructive, non-native ungulate species. As R. Boulon emphasized
(12/12/04), tagged animals will generally be returned to their owners the first time, and perhaps the
second time they have been captured. Animals captured a third time will be either donated for personal
consumption, or humanely euthanized by the most humane and economical means available using a
rifle. When conducting wildlife reduction operations one must consider many views, including the most
humane treatment of captured animals, the most realistic, practical and efficient methods to move
captured wildlife, and the final disposition of captured wildlife. Goats held over three hours

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before overland transportation will be provided drinking water. Goats held overnight will be
provided food and drinking water.

Explanations were included and reiterated in detail in the EA to describe the Preferred
Alternative and to explain the serious and extensive lengths the NPS and USDA Project
Coordinators intend to go to in order to (1) avoid killing any goats or sheep, (2) maximize the
number of animals released to wildlife ranches on St. John, (where most will subsequently be
euthanized and utilized), and (3) use the more stressful methods (such as snares and dogs) only
as a last resort after all other methods have failed.

As a 90-year-old public trust agency, the NPS is required to analyze all reasonable alternatives. The NPS
is also obligated to treat wildlife humanely in all respects, including the capture, transport and (if
necessary) lethal disposition. The NPS has a responsibility to utilize taxpayer funds in a reasonable and
prudent manner, and develop and implement methods to efficiently and reasonably accomplish agency
mandates. It is necessary to balance multiple use scenarios which create the need for compromise.
Because of topography, distances, expense and subsequent limit of boats, trucks and trailers, limited
access or complete inaccessibility, and insufficient human resources, the humane transport of 100% of the
captured animals is impossible, unrealistic, impractical and otherwise inhumane. As stated in the EA, the
transported livestock will be euthanized.

Estimating the percentage of animals likely to be shot in the field, transported alive, transported to a
slaughterhouse or killed by other means would be speculation, at best. These estimates would be
inaccurate and unnecessary for our purposes. Suggesting this estimate be made based on reduction
programs in other parks is unrealistic and unfeasible, as the values and associated parameters are not
comparable and therefore extrapolations could not be made. Our estimate would likely change over time
as well, so specifying the time within which the estimate is valid combined with the fact that some
animals will be soon dispatched when turned over to the rancher further complicates and dilutes the
response. The question mentions VI DNR and the numbers of animals we expect they will dispatch.
DPNR personnel are not permitted to dispatch livestock within the park, thus the question is not
applicable. If the commenter was asking about the number of animals VIDA may be dispatching then our
response is the same as for DPNR. Only certified NPS or APHIS personnel are authorized to dispatch
animals.

It is impossible to determine who owns the livestock, the park suspects some ranchers may come forward
to request free animals, from locations where trailers can be used and accessible from the bush. Only
ranchers participating completely in the Animal Registration and Impoundment Program are
authorized to receive captured livestock, therefore the NPS has no reason to believe ranchers will
dishonestly approach the capture team stating that his goats have been captured. Also if livestock
ranchers knowingly keep goats or sheep inside the park then they are likely not going to tag them. In
more remote areas where humane transport to ranches is unfeasible and thus impractical or
impossible, captured animals would be dispatched and utilized. It is expected that a vast
majority of captured goats and sheep will be transferred to livestock ranches with minimal
recapture.

Given the totality of the setting, topography and location of VINP, it is necessary to fully develop
alternatives, including the consideration of possible (albeit rare) use of tracking dogs or snares and the
possible use of immuno-contraceptives for this project. The EA makes numerous mention of the


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unfeasibility of eradication of goats or sheep from the park. Therefore, mandates must be balanced with
available methods and accomplished as much as possible (the greatest reduction) with the least impact to
the wildlife.

Large-scale wildlife collection operations will be closely coordinated with the public, Virgin Islands
Territorial Government officials, in particular VIDA, NPS Law Enforcement, Interpretation Rangers, and
Maintenance personnel. Resident and visitor safety is of paramount importance, along with the humane
treatment of wildlife during all program operational phases. Direct reduction activities will be well
organized by NPS and USDA Program Coordinators and Law Enforcement authorities. NPS Law
Enforcement personnel and others will ensure proper closure and visitor clearance from each area, as
necessary. Personnel safety will be of greatest concern at all times. Field personnel will be equipped
with both a two-way radio and cellular telephone linked through the newly renovated VINP radio system.
A full-time NPS dispatcher will ensure smooth communication between all essential field personnel.
Most collections will be small-scale operations using single or corral traps.

Biological data will be collected from all captured goats and sheep. Collected goats and sheep will be
turned over to VIDA in many cases, for final disposition with ranchers or for euthanization and public
utilization. Some will be donated by the NPS to island residents strictly for personal (private
consumption). Only ranchers participating in the VIDA Animal Registration and Impoundment Program
qualify to accept captured livestock. In remote locations where transport is impractical or impossible (e.g.
Brown Bay bottom-portion), euthanized goats and sheep will be treated with lime and expected to
completely decompose within one week. This treatment will occur at a minimum of 50 feet from
established VINP trails and an equal minimal distance away from major drainage guts or saltponds. Lime
accelerates the rate of decomposition in the warm, moist subtropical weather; a 100-pound carcass often
completely decomposes within 5 days. On rare occasions when overland transport is impractical and
topography and wetland proximity prevent liming, collected animals will be brought to sea, weighted and
released a minimum of one nautical mile from the shore.

VIDA veterinarians are certified by the USDA to inspect livestock for public consumption for use in a
hospital or prison. Livestock consumed by private individuals does not require VIDA or USDA
inspection, certification or approval. Residents accepting donated meat from the NPS for private
consumption will be required to sign a form stating the guidelines for handling the meat and reiterating
its' use for private consumption (not for resale). Because the public has had a long association with
capturing and utilizing goats and sheep, the NPS has spent considerable energy to ensure collected
animals could be legally and safely provided to them (directly) for private utilization, and for public
utilization through VIDA, in some special circumstances. Field supervisors will ensure personnel
involved in data collection or butchering operations wear protective gloves and avoid contact with
reproductive tracts or fetuses of female goats or sheep. VIDA concurs with this protocol.


9. An Additional Alternative, Remove Goats to a United States Wildlife Sanctuary

Comment: The Fund for Animals is a national animal protection group with over 200,000 members and
supporters throughout the United States. In addition to over our advocacy initiatives, the Fund for
Animals operates the Black Beauty Ranch, a 1,620-acre wildlife refuge in Murchison, Texas. In response
to the Virgin Islands National Park Sustained Reduction Plan for Non-native Goats and Sheep, we would
like to propose an additional alternative to the trapping and killing of these animals.



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In 1979, The Fund for Animals founded Black Beauty Ranch as a home for burros rescued from the
Grand Canyon in response to a National Park Service plan to exterminate them. We worked closely with
the National Park Service to implement a non-lethal approach to managing burros in the Grand Canyon.
The rescued burros have been able to live their lives in a healthy and peaceful setting at Black Beauty
Ranch.

The trapping and killing of wild animals is a cruel and inhumane practice. With non-lethal alternatives,
we encourage the Park Service to consider allowing some of these animals to survive. We respectively
urge the Virgin Islands National Park to consider a similar option for non-native goats and sheep within
the Virgin Islands National Park. Specifically, we are asking that some of these animals be relocated to
wildlife sanctuaries to live out their remaining lives. This will be a tremendous undertaking and the Fund
for Animals will be happy to provide assistance.

There are a number of facilities that take in exotic hoofed animals such as Black Beauty Ranch (Texas),
mini-pigs (Virginia), Performing Animal Welfare Society (California), and the Rocky Mountain Wildlife
Conservation Center (Colorado). These refuges were established to help animals whose lives are
threatened, such as the exotic goats and sheep in the Virgin Islands National Park. Options for relocation
include several phases combined with sterilization and contraceptive use to ensure zero population
growth. Each phase a significant portion of animals could be relocated to wildlife refuges and sanctuaries
until they are all removed. This will allow the Virgin Islands National Park to achieve a goal of reducing
exotic goats and sheep in a humane manner.

Thank for your time and consideration of these comments and our proposed non-lethal alternative. Please
do no hesitate to contact me with any questions or for additional information. Look forward to hearing
from you.

Response: The referenced Fund for Animals program is extremely successful and provides a viable,
realistic opportunity for a great number and diversity of wildlife to live out their natural lives in a
sanctuary. Many of the animals arrive from distant lands including other continents. Their critical review
of the EA was welcomed. One EA author contacted their respondent to clarify some key points in the
suggestion; this conversation resulted in their essential withdrawal of the suggestion to relocate goats to a
Texas wildlife sanctuary. This change occurred when the FFA understood the full context of the NPS
preferred alternative discussed in the Draft EA, and the parameters within which the project is occurring
in the Virgin Islands. Clarified were the following facts: (1) the goats and sheep are ancestors of those
released or escaped from local wildlife ranches where they are euthanized and utilized, (2) the vast
majority of collected animals will be humanely provided to wildlife ranches, (3) the small proportion of
animals unsuitable for Item 2 above will be humanely euthanized and utilized, and (4) only a small
percentage will be in locations where item 3 above is impractical or impossible.

Captured animals which cannot be humanely transported to livestock ranches or directly euthanized and
transported for personal consumption on St. John are expected to be few in number. However, this
number would not be considered for transport over 1000 ocean miles and trucked another several hundred
miles. The trip would be an expensive challenge with questionable humanity. Finally, those animals who
survive the expensive and intensive sea journey would be expected to live but a few years. Long distance
transport such as this might be most appropriate for long-lived species or extremely rare and endangered
wildlife. To accomplish this monumental, expensive and logistically challenging task on a recurring
basis, for relatively short-lived livestock, from extremely remote locations, challenges logic and
humanity. Again, a majority will be relocated to wildlife ranches in St. John, but some must be utilized in
the field rather than at the livestock ranch for logistical and humanity reasons. Only a relative small

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percentage is expected to be euthanized and left unutilized. Because they may well die, or otherwise
suffer for days in transit, the preferred and humane alternative is also the practical approach: humane
removal from Park lands.

In summary, the lead author of the EA spoke with a FFA official to offer clarification. When the FFA
official understood the full context of the EA, and especially the final disposition, the FFA official
concurred with NPS that the most humane option for the vast number of goats is what the NPS proposed
as the Preferred Alternative in the Draft EA. Much of what the author informed the FFA representative
was in the Draft EA but the FFA was unaware of the information. A majority of goats are expected to be
live-captured and relocated to wildlife ranches in St. John or St. Thomas, provided the ranchers adhere
fully to the USVI Animal Registration and Impoundment program. The FFA official and EA author were
in full agreement this was preferable to having the goats shipped to Texas and trucked to a sanctuary.
Neither the FFA nor the NPS have the funds to conduct this operation, but both agreed if some funding
were available, the animals would be better off staying in the Virgin Islands, because of the (1) duration
of travel, (2) hardship to the animals and (3) expense of travel (and holding beforehand), (4) challenging
logistical concerns, (5) relatively short-lived, and (6) extremely common species. Additionally, those
funds would then be unavailable for other FFA or NPS purposes.

We also discussed the final disposition in extreme detail and agreed some goats would require shooting.
We agreed the goats and sheep originated as ranch animals which by definition are subject to slaughter.
The FFA official was pleased that a majority of animals are expected to be removed live from the park,
but concurred that in some remote locations they would be dispatched and removed for consumption.
This was believed more humane than transporting some of the animals live, over long, costly distances,
only to dispatch them upon arrival at the ranch. Finally, we agreed that some extremely remote locations
necessitated the use of lime or sea burial, because the animals could not be humanely brought out alive
not logistically removed after dispatching, because to do so is impractical.

For these reasons, the NPS rejected the primary suggestion from FFA as the result of the conversation
described immediately above. FFA essentially withdrew the proposition when they fully understood our
rationale, objectives, and the final disposition. Their suggestion was essentially withdrawn because FFA,
armed with a more complete understanding of the methodology to be used, and scope of logistics and
practicality, ultimately agreed with the NPS preferred alternative




















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