Title: Final environmental assessment : sustained reduction plan for non-native rats, cats and mongooses from Virgin Islands National Park
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Title: Final environmental assessment : sustained reduction plan for non-native rats, cats and mongooses from 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: 2002
 Subjects
Subject: Caribbean   ( lcsh )
Spatial Coverage: North America -- United States Virgin Islands -- Saint John -- Virgin Islands National Park
Caribbean
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Bibliographic ID: CA01300647
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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VIRGIN ISLANDS NATIONAL PARK



FINAL
ENVIRONMENTAL ASSESSMENT







Sustained Reduction
Of
Non-native Rats, Cats And Mongooses
From
Virgin Islands National Park



DEPARTMENT OF THE INTERIOR
NATIONAL PARK SERVICE
SOUTHEAST REGION


MARCH 2002










This Final Environmental Assessment (EA) evaluates impacts from non-native rats, cats and mongooses
in Virgin Islands National Park, describes control alternatives and proposes actions to reduce their
populations. By reducing their population size inside the Park, adverse impacts to visitors, residents and
natural and cultural resources will also decrease. Collectively, non-native rat, cat and mongoose
populations pose a very large threat to the native natural resources, long-term resource management
programs of the Park, and visitor health and safety. The Final EA document has been prepared in
response to comments and concerns received during the public review of the Draft EA.

Availability
The Final Sustained Reduction of Non-native Rats, Cats and Mongooses from Virgin Islands National Park
Environmental Assessment is available for public viewing at the following locations:


Elaine I. Sprauve Public Library Enid M. Baa Public Library
St. John, VI St. Thomas, VI


VINP Visitor Contact Station National Park Service Headquarters
Cruz Bay; St. John, VI Christiansted NHS; 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 the following address:


Resource Management Division
National Park Service
Virgin Islands National Park
1300 Cruz Bay Creek
St. John, Virgin Islands 00830
Rafe Boulon(-nps.gov
(340) 693-8950 x 224











As the nation's principal conservation agency, the Department of the Interior has responsibility for most of our
nationally owned public lands and natural and cultural resources. This includes fostering the wisest use of our land
and water resources, protecting our fish and wildlife, preserving the environmental and cultural values of our
national parks and historic places, and providing for enjoyment of life through outdoor recreation. The department
assesses our energy and mineral resources and works to assure that their development is in the best interests of all.
The department also has a major responsibility for American Indian reservation communities and for people who
live in island territories under U.S. administration.


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TABLE OF CONTENTS



I. CHAPTER I. PURPOSE AND NEED 7

A. Introduction 7
B. Purpose and Need 7
1. Program Objectives: Sustained Reduction 12
C. Proposed Action 12
1. Steps Required for Sustained Reduction 13


II. CHAPTER H. ALTERNATIVES 16

A. Non-native Rat Control Alternatives 16
1. Non-Native Rat Control Techniques 16
2. Alternative 1. No Action, Continue Current Level of Management 21
3. Alternative 2. Proposed Action Sustained Reduction 21

B. Non-native Cat Control Alternatives 23
1. Non-native Cat Control Techniques 23
2. Alternative 3. No Action, Continue Current Level of Management 25
3. Alternative 4. Proposed Action Sustained Reduction 26

C. Non-native Mongoose Control Alternatives 27
4. Non-native Mongoose Control Techniques 27
5. Alternative 5. No Action, Continue Current Level of Management 28
6. Alternative 6. Proposed Action Sustained Reduction 28


III. CHAPTER HI. AFFECTED ENVIRONMENT 30

A. Natural Resources 30
1. Setting 30
2. Wetlands and Floodplains 31
3. Terrestrial Vegetation 32
4. Native Animals 32
5. Endangered/Threatened Species 33
6. Introduced Animals and Plants 34

B. Natural Resources Threats 35
1. Land Use and Boundary Issues 35
2. Visitation Issues 36
3. Threats to Endangered and Threatened Species 36
4. Non-native/Exotic Animal Impacts 37

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5. Non-native Norway and Tree Rat Impacts 37
6. Non-native Domestic Cat Impacts 40
7. Non-native West Indian Mongoose Impacts 42
8. Biological Pollution (Exotic Plants) 44
9. Forest Recovery, Fragmentation Vegetation Removal 44
10 Garbage Disposal and Recycling 45

C. Cultural Resources 45
1. History 45
2. Archeological Sites 46
3. Historic Structures 47


IV. CHAPTER IV. ENVIRONMENTAL CONSEQUENCES 50

A. Non-native Rat Control Environmental Consequences 50

Alternative 1. No Action, Continue Current Level of Management 50
1. Air Quality Impacts 50
2. Scenic Values 50
3. Cultural Resource Impacts 50
4. Socioeconomic/Visitor Use Impacts 50
5. Soil Impacts 50
6. Threatened & Endangered Species Impacts 51
7. Vegetation Impacts 51
8. Wildlife Impacts 51
9. Water Quality Impacts 51
10. Wetland/Floodplain Impacts 51
11. Park Operations Impacts 52
12. Cumulative Impacts 52

Alternative 2. Proposed Action Sustained Reduction 52
1. Air Quality Impacts 52
2. Scenic Values 52
3. Cultural Resource Impacts 53
4. Socioeconomic/Visitor Use Impacts 53
5. Soil Impacts 53
6. Threatened & Endangered Species Impacts 53
7. Vegetation Impacts 54
8. Wildlife Impacts 54
9. Water Quality Impacts 54
10. Wetland/Floodplain Impacts 54
11. Park Operations Impacts 54
12. Cumulative Impacts 54



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B. Non-native Cat Control Environmental Consequences


Alternative 3. No Action, Continue Current Level of Management 55
1. Air Quality Impacts 55
2. Scenic Values 55
3. Cultural Resource Impacts 55
4. Socioeconomic/Visitor Use Impacts 55
5. Soil Impacts 56
6. Threatened & Endangered Species Impacts 56
7. Vegetation Impacts 56
8. Wildlife Impacts 56
9. Water Quality Impacts 56
10. Wetland/Floodplain Impacts 56
11. Park Operations Impacts 57
12. Cumulative Impacts 57

Alternative 4. Proposed Action Sustained Reduction 58
1. Air Quality Impacts 58
2. Scenic Values 58
3. Cultural Resource Impacts 58
4. Socioeconomic/Visitor Use Impacts 58
5. Soil Impacts 58
6. Threatened & Endangered Species Impacts 58
7. Vegetation Impacts 58
8. Wildlife Impacts 59
9. Water Quality Impacts 59
10. Wetland/Floodplain Impacts 59
11. Park Operations Impacts 59
12. Cumulative Impacts 59


C. Non-native Mongoose Control Environmental Consequences 60

Alternative 5. No Action, Continue Current Level of Management 60
1. Air Quality Impacts 60
2. Scenic Values 60
3. Cultural Resource Impacts 60
4. Socioeconomic/Visitor Use Impacts 61
5. Soil Impacts 61
6. Threatened & Endangered Species Impacts 61
7. Vegetation Impacts 61
8. Wildlife Impacts 61
9. Water Quality Impacts 62
10. Wetland/Floodplain Impacts 62
11. Park Operations Impacts 62
12. Cumulative Impacts 62

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Alternative 6. Proposed Action Sustained Reduction 63
1. Air Quality Impacts 63
2. Scenic Values 63
3. Cultural Resource Impacts 63
4. Socioeconomic/Visitor Use Impacts 63
5. Soil Impacts 63
6. Threatened & Endangered Species Impacts 63
7. Vegetation Impacts 64
8. Wildlife Impacts 64
9. Water Quality Impacts 64
10. Wetland/Floodplain Impacts 64
11. Park Operations Impacts 64
12. Cumulative Impacts 64

D. Comparison of Alternatives 66


V. CHAPTER V. COMPLIANCE WITH ENVIRONMENTAL LAWS
AND REGULATIONS 72

VI. CHAPTER VI. CONSULTATION AND COORDINATION 74

VII. CHAPTER VI. PLANNING TEAM / PREPARERS 75

VIII. CHAPTER VII. REFERENCES CITED 76

IX. CHAPTER X. APPENDICES 80

A. List of Endangered Plants and Animals of the U.S. Virgin Islands 81
B. List of Introduced Animals to St. John Island, U.S. Virgin Islands 84
C. Sample Eaton Bait Blocks Rodenticide 24c Label 85
D. The Wildlife Society Position Statement Concerning Feral Domestic Cats 86
E. Consultation Letter from U. S. Fish and Wildlife Service 87
















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I. CHAPTER I. PURPOSE AND NEED


I.A. INTRODUCTION

The purpose of this document is to evaluate the short-and long-term environmental consequences of a
sustained reduction of non-native rats (Norway Rat, Rattus Norgegicus and Tree Rat, Rattus rattus), non-
native Domestic Cats (Felis catus), and non-native West Indian Mongooses (Herpestes auropunctatus)
from Virgin Islands National Park, St. John, U.S. Virgin Islands.

NPS Natural Resources Management Guidelines (1991, Chapter 2, Page 286) require that for each non-
native species present within a National Park Service unit, an individual management and monitoring
program be tailored to the particular park setting. This program includes a species evaluation,
development of an information base, monitoring, initiation of management actions, and establishment of
an institutionalized follow-up program.

National Park Service guidelines for compliance with the National Environmental Policy Act (NEPA)
require an analysis of potential effects of this from the proposed activity on the affected environment.
This environmental assessment reviews these potential impacts and the actions that would be taken to
prevent and/or mitigate any adverse effects. As described in Section I.C, the National Park Service in
cooperation with the U.S. Department of Agriculture's Animal Plant Health Inspection Service / Wildlife
Services Division, proposes to conduct an island-wide non-native rat, cat and mongoose reduction
program using a combination of trapping or rodenticide applications within Virgin Islands National Park.


I.B. PURPOSE AND NEED

The purpose of the proposed action is to undertake a sustained reduction of non-native rats, cats and
mongooses from Virgin Islands National Park. By reducing their population size inside the Park, adverse
impacts to visitors, residents and natural and cultural resources would decrease. The program purpose is
to reduce non-native rat, cat and mongoose populations to levels where they produce minimal or no
damage to Park resources or threats to visitor and employee safety. The program is therefore, termed a
"sustained reduction," because once the non-native rat, cat and mongoose populations are reduced to
acceptable levels, the smaller populations would be maintained at that level or below. Collectively, non-
native rat, cat and mongoose populations pose a very large threat to the native natural resources, long-
term resource management programs of the Park, and visitor health and safety.

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 (Stone and Loope
1996). It is now widely accepted that the current rates of species extinctions 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 (Soule 1990).

Results of the first three categories are often acute and can directly affect human and native wildlife
welfare on an observable time scale. The human related impacts have made them the focus of public
environmental concem. The introduction of non-native species has received less publicity and
professional attention; however, introduced species are responsible for 39% of all recorded animal
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extinctions since 1600 for which a cause could be attributed (Treshy and Croll 1994). Thus, some
impacts of introduced species are irreversible and at least as devastating as the other categories. Once
established, introduced species often become permanent in ecological time unless intentionally removed
(Treshy and Croll 1994).

Native wildlife in island ecosystems are particularly vulnerable to the first three categories as well as the
impacts of introduced species. 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, calculated from the World
Conservation Monitoring Centre 1992).

Islands are important for the conservation of biodiversity for four reasons: 1) a large percentage of their
biota are endemic species and subspecies; 2) they are important breeding areas for seabirds, pinnipeds,
and sea turtles, which forage over thousands of square kilometers of ocean but are dependent on relatively
small amounts of protected land on islands for breeding and nesting; 3) many islands are sparsely
inhabited or uninhabited by humans, keeping socioeconomic costs of protection low; 4) the species and
ecological communities on islands have evolved in natural fragments, making them less susceptible than
continental species to the problems of habitat fragmentation caused by small reserve size. In summary,
by restoring and protecting islands, functioning unmanaged ecosystems can be maintained without large
expenditures or significant conflict with local human populations (Treshy and Croll 1994).

Wild animals, which establish breeding populations after being introduced by humans, are termed exotic.
Feral animals, by contrast, are introduced from domestic animals and establish breeding populations in
the wild. Exotics are generally more frightened of humans, while feral animals can be very friendly to
people. For simplicity purposes, all animals that establish breeding populations in the Park will be called
"non-native." All of these species disrupt complex native ecological communities, jeopardize endangered
and native plants and animals, and degrade natural habitats.

Because the Park boundary is entirely coterminous with private or territorial lands, non-native animals
readily enter from adjacent lands. Also, several hundred inholdings exist within the Park's authorized
boundary, and many have residences. Thus, non-native animals inhabiting adjacent lands would always
enter the Park and attempt to establish breeding populations. For these reasons, the permanent
elimination (eradication) of non-native rats, cats or mongooses from the Park is impossible and thus not
analyzed as an alternative. Therefore, feasible alternatives must focus on regular efforts to reduce the
population size and minimize concomitant and cumulative impacts from each species. The key is to
manage populations in an Integrated Pest Management (IPM) approach that includes regular inspections
and monitoring, upgraded sanitation, retrofitting trash receptacles, rat-proofing structures, and other
measures.

The National Park Service Organic Act (16 U.S.C. 1 et seq [1988], August 25, 1916, sc. 408, 39 Stat.
535) mandates the parks to "conserve the scenery and the natural and historic objects and the wildlife
therein... {to} leave them unimpaired for the enjoyment of future generations." Changes to the natural
communities from human actions in the parks, including the continuous and unabated invasion of exotic
and feral species, are contrary to the intentions of the Act. Additionally, the NPS Organic Act, especially
16 U.S. C 3, authorizes the Secretary of the Interior to destroy animals that may be detrimental to parks;
therefore comprehensive control of exotics and their effects in the NPS is therefore compulsory.

NPS is mandated to destroy animals that are 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. High priority will be given to

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the management of exotic species that have a substantial impact on Park resources and that can be
expected to be successfully controlled (NPS Natural Resources Management Guideline 1991, Chapter 2,
Page 286).

The National Park Service is required to identify and promote the conservation of all Federally listed
threatened, endangered, or candidate species within park boundaries and their critical habitats (see
Appendix A, List of Endangered Plants and Animals of the U.S. Virgin Islands). The National Park Service
is also required to protect all state and locally listed threatened, endangered, rare, declining, sensitive, or
candidate species that are native to and present in the Parks, and their critical habitats (NPS Management
Policies 2001; VINP General Management Plan (1983), pages 47-48). Guidelines for management of
species Federally listed as threatened, endangered or candidates for listing are found in NPS management
policies and natural resources management guidelines, National Park Service Management Policies (NPS
2001) and guidelines for natural resources management (NPS Natural Resources Management Guideline
1991, Chapter 2, Pages 268-279) establish the affirmative responsibility of NPS, and the individual Park,
for managing both listed and candidate species. They also stress that management actions should
emphasize removal of threats, but also active recovery efforts and that management should be done in an
ecosystem context.

The Endangered Species Act (ESA) requires that actions authorized, funded or carried out by Federal
agencies not jeopardize the continued existence of listed species. Under section 7(a)(2) of the ESA (16
USC section 1536), Federal agencies are required to consult with the U. S. Fish and Wildlife Service
(USFWS) on actions which may affect listed species or critical habitat. Because this primary restoration
plan proposes actions that may affect the 3 Federally listed plant species and 8 Federally listed wildlife
species on St. John Island, NPS consulted with USFWS on likely effects to those species (Appendix E).
The Sea Turtle Recovery Plans stipulate that predators should be removed from turtle nesting beaches to
protect species listed under the authority of the Endangered Species Act. The USFWS determined that
this proposed action will have no impact on listed species or migratory birds, in fact, it will most likely
greatly benefit them.

With the exception of bats, the Virgin Islands National Park is presently inhabited by numerous species of
non-native mammals that have produced severe impacts on many indigenous species of plants and
animals and threats to visitor safety (Appendix B). Feral or wild mammals include the white-tail deer,
donkey, wild hog, domestic goat, domestic cow, domestic sheep, European boar, West Indian mongoose,
tree rat, Norway rat and domestic cat, domestic dog and house mouse. Some of these species also
threaten visitor experience and safety. With the possible exception of deer, 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 impacting the fragile environment (see
Appendix B, List of List of Introduced Animals to St. John Island).

Norway Rats or Brown Rats (Rattus norvegicus) existed on St. John from the 1700's and were introduced
by European explorers. Black or Tree Rats (Rattus rattus) existed on St. John from the earliest records
and were also introduced by Europeans. Both species occur in Virgin Islands National Park and range
throughout St. John, but the tree rat is considerably more common. Most problems arise from the
nocturnal black rats, which reside in trees and generally forage at night. Tree rats are associated largely
with people and human establishments and are known as commensal rodents.

As commensal rodents, Norway and tree rats are habituated to living near humans and except for an
occasional predation by red-tailed hawks, they have no biological predators. Rats are omnivorous; they
eat nearly every kind of grain, fruit, fish, fowl, carrion, milk products, and vegetables. Several rodents
can destroy hundreds of chicks in just one night. They are behaviorally plastic, have high reproduction

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rates, and can survive in a variety of habitats. These traits make them ideally suited to survive on a
variety of predator free islands. Even if extinctions do not occur, rats can have ecosystem wide effects on
the distribution and abundance of native species through direct and indirect effects. For example,
comparisons of rat-infested and rat-free islands, or pre and post rat eradication experiments, have shown
that rats depressed the population size and recruitment of birds, reptiles, plants and terrestrial
invertebrates. Rats have also been shown to affect the abundance and age structure of intertidal
invertebrates. The introduction of new Rattus species should be avoided, even to islands that already
have introduced rats.

Domestic cats originated from an ancestral wild species, the European and African Wild Cat (!elis
silvestris). The Domestic Cat (Felis catus) is now considered a separate species. The estimated numbers
of pet cats in urban and rural regions of the United States have grown from 30 million in 1970 to early
65 million in 2000. Reliable estimates of the present total cat population are not available. Nationwide,
approximately 30% of households have cats. In rural areas, approximately 60% of households have cats.
Populations of birds on oceanic islands have evolved in circumstances in which predation from
mammalian predators was negligible and they, and any other island vertebrates and invertebrates, are
therefore particularly vulnerable to predation when non-native cats have been introduced.

The impacts of domestic cats on wildlife are difficult to quantify. However, a growing body of literature
strongly suggests that domestic cats are a very large factor in the mortality of small mammals, birds,
reptiles and amphibians. Because free-ranging cats dften receive food from humans, they can reach
population levels that may create areas of abnormally high predation rates on wildlife. When the wildlife
prey is a threatened or endangered species, the results may be extirpation or extinction. Effects of cat
predation are most pronounced in island settings (both actual and islands of habitat), where prey
populations are already low or stressed by other factors, or in natural areas where cat colonies are
established.

Non-native cats have and continue to threaten populations of reptiles and ground and shrub nesting birds
as well as providing vectors for transmission of parasites and diseases to humans. Cats carry many
diseases, some which may be passed to humans (cat scratch fever, various bacterial skin diseases) and
others that are transmissible to domestic cats. Certainly, their feet and fur carry germs, which they
invariably disperse in their wanderings. Cats also apparently like to defecate in the bathrooms and
showers at Trunk Bay, producing very unsanitary conditions and additional work for Park employees.
Several visitors have contracted "creeping eruption"(Tinea corporis, also known as ringworm), a fungal
infection, while on the beach at Trunk Bay. This is transmitted via cat feces, probably deposited on the
beach where conditions are favorable for bacterial survival.

Cats hunt for both fun and food. Unlike wild predators, domestic cats hunt whether they are hungry or
not. These cats are called "subsidized predators" because they sometimes receive a steady supply of food
at home. Pet cats can hunt longer and are less susceptible to disease than many wild predators. Because
non-native cats routinely kill insects and other small animals for "sport" to practice their hunting skills, in
addition to using them as a food source, great numbers of wildlife are lost each year to a small cat
population. A recent university study in Wisconsin ((Fish and Wildlife Today 1998) estimated that 1 to
2 million free ranging rural cats in Wisconsin kill roughly as many as 217 million birds each year."
Researchers noted that birds make up only 20 percent of the cats' diet. Seventy percent of the diet was
small mammals and 10 percent reptiles and amphibians (Patronek 1997; Coleman and Temple 1995).
Thus, great numbers of wildlife can be lost each year to a small non-native cat population.

In the 1880's, European planters introduced the West Indian Mongoose (Herpestes auropunctatus) to the
Caribbean and to St. John as a biological control to suppress the tree rat populations that decimated sugar

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cane fields (Nellis and Everard 1983). It was thought to be the salvation for the large sugar cane
plantations on the islands that were being ravaged by tree rats. At first, the statistics indicated that a very
large decline in the rat population had occurred and the decline was attributed to mongoose predation. As
a result, in the next 30 years (1872 to 1900), even more mongooses were brought to the islands and
distributed throughout the Caribbean as a biological control.

Soon it was discovered that rats that sought out their meals at night didn't cross paths with the daytime
foraging mongooses. Rats are nocturnal and sleep in trees during the day. They were therefore able to
eat as much sugar as they wanted ly night, while the mongooses were sleeping. The rats were safe,
during the day, from the mongooses, which cannot climb trees. They coexist well and we now have both
non-native species to contend with. Mongoose populations are scattered throughout St. John, with the
highest concentrations near human populations, due to increased food availability. Mongooses have no
biological predators and populations rise sharply when sufficient food quantities become available (Nellis
and Small 1983).

Problems compounded as the rats continued to enjoy sugar cane and mongooses feasted instead on bird
and sea turtle eggs, as well as, insects, papaya and guava. Public health concerns increased when the
mongoose was discovered to be a carrier of rabies. Since mongooses have no natural predators here, the
checks and balances of natural population control are missing. Non-native mongoose have devastated
reptile populations, some bird populations and continue to depredate the nests of the endangered
Hawksbill Sea Turtle (Coblentz, 1983).

Because reptiles, amphibians and invertebrates, such as insects, are small, often slow and readily available
on St. John, they are particularly susceptible to local extinction from non-native rat, cat and mongoose
depredation. Of particular concem are the varied native reptile and amphibian populations in the Virgin
Islands National Park and their links to the ecological web of the island. Non-native rats, cats and
mongooses prey upon three species of tree frogs, two geckos, three Anolis lizards, the Ground Lizard,
Legless Lizard, Blind Snake, the Puerto Rican Racer, and the Slipperyback Skink. The Park has listed
over 232 common insect species, including 13 species of dragonflies and damselflies and over 1,500
beetle species; all of which may be eaten by rats, cats and mongooses.

Great numbers of wildlife, therefore, are lost each year to relatively small non-native rat, cat and
mongoose populations. The cumulative impacts associated with these increasing wildlife loses are very
large. 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.

Non-native rats, cats and mongoose prey upon endangered Hawksbill and Leatherback sea turtles, which
nest on St. John. Norway and roof rats, cats and mongoose kill emergent hatchlings as they crawl from
the nest to the ocean at night, when the rats are most active. Non-native rats, cats and mongoose will also
prey upon sea turtle nests soon after being laid when the odor is still present, eating many eggs and
spoiling the remaining ones. The Sea Turtle Recovery Plans stipulate that predators should be removed
from turtle nesting beaches in order to protect species listed under the provisions of the Endangered
Species Act.

Non-native rats, cats and mongooses prey upon chicks, juveniles and adults of most bird species that nest
on St. John. Of particular concern are endangered Brown Pelicans, Least Tems and threatened Roseate
Tems. Territorial endangered species preyed upon by non-native rats, cats and mongoose include ground
and tree nesting species such as Bridled Quail Dove, Bahama Pintail Duck, and the Antillean Mango

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Hummingbird, all of which suffer egg and chick death due to rats. Non-native rats, cats and mongoose
also prey upon four (of the five) native bat species, three of which are territorially endangered, and the
only indigenous mammals on the island.

The Virgin Islands National Park General Management Plan (1983) and Resource Management Plan
(RMP) (1999) identified the need to remove non-native animals from St. John Island. RMP objectives for
management of non-native rats, cats and mongooses in Virgin Islands National Park, include:

1. Protect the native species and natural processes of the Park's ecosystems by reducing the
impacts of non-native rats, cats and mongooses on these species and processes.

2. Protect critical habitat of rare, endangered, and endemic species, and reduce non-native rat,
cat and mongoose impacts on identified areas that are particularly vulnerable to predation and
disturbance.

3. Protect rare, endangered and endemic species, which are presently or potentially affected by
activities of non-native rats, cats or mongooses.

4. Ensure the opportunity for visitor experience of undisturbed natural processes by reducing the
effects of non-native rats, cats and mongooses' activity upon aesthetic and wildemess values
of the Park.

5. Protect public health by monitoring non-native rats, cats and mongoose populations and
individual animals for possible diseases communicable to humans, livestock or wildlife.

6. Minimize adverse effects of non-native rats, cats and mongooses control methods upon
natural, cultural and human resources adjacent to the Park.


I.C. PROPOSED ACTION

The National Park Service in cooperation with the U.S. Department of Agriculture's Animal Plant Health
Inspection Service / Wildlife Services Division proposes to conduct a site-specific non-native rat, cat and
mongoose population reduction program using a combination of trapping, rodenticide applications and
other cultural practices within Virgin Islands National Park. In general, non-native rat, cat and mongoose
populations are larger in or near areas of human development, in part because of the availability of food,
and lowest in remote areas with few human dwellings or visitors. Key steps for a viable management
plan include: 1) establish current and acceptable population estimates; 2) identify food sources, methods
to reduce available food and habitat; 3) develop strategies for population reduction; 4) public education;
5) long-term monitoring; and 6) periodic removal. The approach must be integrated and include
partnerships with concessionaires, adjacent landowners/inholdings and relevant community groups.
Public education, monitoring and maintaining partnerships must be accomplished over the long-term.

Especially essential would be reduced harborage and building access for rats, cessation of cat disposal and
feeding on Park lands by residents, and elimination of human-created food resources for all three species.
Large populations can only exist if sufficient food is available. Therefore, when the food supply is
reduced, the population would fall. Increased sanitation, more frequent trash pick-up, animal-proofed
trash receptacles, and enhanced food preparation and storage practices would all reduce food availability.
These actions must be well established before a large-scale population reduction effort is initiated. Habitat
reduction methods are very important to limit population growth, particularly with non-native rats.
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Changing landscaping practices and sealing access to buildings are inexpensive remedies for habitat
reduction. Periodic inspections by qualified personnel are necessary to minimize new harborage and
rodent access.

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

Total eradication is impractical and impossible as a feasible alternative due to the size of St. John and the
large number of inholdings. Therefore, efforts would focus on sustained control of the non-native rat, cat
and mongoose populations and a concomitant reduction in their impacts on natural resources. To achieve
this goal, a combination of techniques would be initiated in three phases. In he first phase, various
techniques would be employed to reduce harborage and food resources for the present populations.
Significant consensus-building efforts with various community groups will also occur. In phase two,
techniques would be used to quickly reduce populations to acceptable levels at sites such as Hawksnest,
Trunk, Cinnamon, Francis, Saltpond and Lameshur bays, and Annaberg. Phase three would be to monitor
and remove individuals that exceed threshold levels, continue partnerships and provide education on a
continual basis.


I.C.1. STEPS REQUIRED FOR SUSTAINED REDUCTION

PHASE I- Planning, Logistics, Consensus-Building, Food/Habitat Reduction

1. Prepare an Environmental Assessment for Non-native Rat, Cat and Mongoose Reduction.

2. Establish general human activity zones and tolerance limits for each zone and species.

3. Monitor food and trash (both food and non-food) handling and storage facilities, areas, practices,
receptacles and schedules throughout the Park.

4. Inspect landscaping and buildings in high and medium human use zones with specific attention to
non-native rat, mongoose and cat harborage, usage and access.

5. Develop a basic Non-native Rat, Cat and Mongoose Action Plan. Initiate and develop significant
consensus-building efforts with local wildlife groups including the Audubon Society, St. John
Animal Care Center, Humane Society of St. Thomas/St. John and the Environmental Association
of St. Thomas/St. John.

6. Educate key NPS and concessionaire personnel about the Action Plan.

7. Implement measures within the Park to reduce harborage, food availability and food/building
access by non-native rats, mongooses and cats (by a combination of methods):

a. Comprehensive inspections;
b. Mechanical rodent-proofing techniques;
c. Revise schedules to increase the frequency of trash pickup;
d. Curtail non-native cat feeding practices;
e. Issue and require campers to use rodent-proof containers in the campground;
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f. Retrofit all trash receptacles to exclude non-native rats, cats and mongooses; and
g. Improve food storage facilities.


PHASE II- Quick Population Reduction

After implementing Phase I, conduct large-scale direct reduction efforts to rapidly and substantially
reduce non-native rat, cat and mongoose populations until acceptable population limits are achieved in
cooperation with the U. S. Department of Agriculture's Animal Plant Health Inspection Service/ Wildlife
Services Division.

For non-native Norway and roof rats, Phase II would consist of a initial single, large scale direct
reduction using bait stations with diphacinone or baited live traps throughout the Park. Follow-up
trapping/census would reduce populations by approximately 80% of what their current
populations are estimated to be through an initial snap-trap census. The trap census technique
(Witmor, 1998) will be employed for this estimate. Rat populations would be monitored and
maintained at acceptable levels with continued trapping and use of bait stations.

For non-native cats, Phase II consists of an initial, single, large-scale direct reduction using live
traps followed by adoption where possible. The Park will assist the St. John Audubon Society to
register domestic cats using free ear-tags and break-away collars. A St. John veterinarian has
offered to tattoo ears of domestic cats for the cost of anesthesia. Any collared or tattooed animals
will be returned to their owners. Unmarked animals will be provided to the St John Animal Care
Center (SJACC). Cats testing positive for Feline Immunodeficiency Virus or Feline Leukemia
Virus will be destroyed by American Veterinary Medical Association (AVMA) approved
methods. Veterinarians working for or subsidized by the SJACC will sterilize cats testing
negative for those viral diseases and clip their left ear. These cats will be placed for adoption or
released to a feeding station outside the Park boundary. Cats that are recaptured twice after they
were treated and released by SJACC will be given to the Humane Society of St. Thomas and St.
John.

Follow-up census/trapping efforts would attempt to remove approximately 100% of the 15-30
existing non-native cats at such sites as Trunk, Cinnamon and Francis Bays and Annaberg.
Initially, efforts would be made with interested individuals to remove cats from throughout ihe
Park prior to trapping. Traps would be checked at no greater than 6-hour intervals so cats are
subjected to minimal stress.

For non-native mongooses, Phase II would consist of a single, large scale direct reduction using
live traps baited with chicken or sardines at selected sites throughout the Park,. Follow-up
census/trapping would reduce populations by approximately 80% of what their current
populations are estimated to be. This approximation is based on survey estimates from Nellis and
Evererd (1983), who found intensive trapping over the short-term yielded about 80% of the local
mongoose population to an acceptable level. Captured mongooses will be humanely euthanized
using sodium pentabarbatol or other AVMA approved methods.


PHASE III Monitor the Sustained Reduction

1. Monitor non-native rat, cat and mongoose populations, harborage, food availability, trash collection
schedules, etc. regularly, using checklists. Cat and mongoose populations will be monitored using

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standard visual census techniques in centers of high human activity on a periodic basis. Feeding of
wildlife within the Park must be discontinued. Rats will be trap-censused as described elsewhere, on
a periodic basis.

2. Maintain monitoring logs, continue routine building inspections, continue successful landscaping
practices, and maintain comprehensive and accurate records.

3. Work effectively and cooperatively with partners including concessionaires, residents and visitors on
an ongoing basis. Relationships must be continued as key directors or managers change in the
numerous governmental and non-governmental organizations (NGO's). Develop a comprehensive
educational campaign with the partners and together routinely disseminate the information through a
variety of media including newspaper, radio, and the Internet.


The timeframe for implementing each phase of the sustained reduction program would be: Phase I and
Phase II concurrent for the next twelve months starting in April or May 2002; and Phase III would
monitor the populations and other implemented changes, such as habitat and food, indefinitely. The
educational component and continued partnerships must be sustained indefinitely.




































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II. CHAPTER II. ALTERNATIVES


The National Environmental Policy Act (NEPA) requires that a reasonable range of alternatives be
developed to provide decision-makers and the public with a clear basis for choice (40 CFR 1502.14).
Case law has determined that reasonable alternatives include those that are technically and economically
practicable and feasible, using common sense, rather than those that are simply desirable (46 CFR 18027,
Forty Most Asked Questions Concerning CEQ's NEPA Regulations).

The alternatives detailed below were developed to focus on issues identified by NPS resource specialists
NPS, rat and mongoose reduction experts and other control experts, government regulatory agencies, and
the general public. Chapter VI, Consultation and Coordination list all individuals, agencies and
organizations that provided substantive comments regarding the proposed actions.

This chapter describes six alternatives that are analyzed for control of non-native rat, cat and mongoose
populations in Virgin Islands National Park. Following a brief description of control techniques for each
species, the same two alternatives are described for each species as follows:

Rat control (1) no action, continue current level of management, and (2) the proposed action;
cat control (3) no action, continue current level of management, and (4) the proposed action; and
mongoose control (5) no action, continue current level of management, and (6) the proposed action.

The alternatives are numbered sequentially for comparison purposes. As required by NEPA, Alternatives
1, 3 and 5 are included as a "No Action" alternatives, serving as benchmarks against which other action
alternatives can be compared. These alternatives represent the state of the management of these non-
native wildlife populations within Virgin Islands National Park at this point in time.



II.A. Non-native Rat Control Alternatives

II.A.1. Non-native Rat Control Techniques

This section describes the primary mechanical, chemical techniques and other cultural practices for an
extensive and rapid population reduction effort for non-native rats.

Mechanical Live Trap and Euthanization

Captured animals must be killed because to relocate them would only transfer the problem elsewhere.
This section describes various methodologies to capture and euthanize non-native rats. Extensive live
traps are placed along designated trap lines transectss) and baited with fish flavorizer. Measures are taken
to reduce nontarget captures of hermit crabs, birds, etc. (i.e. elevation of baits, bait site selection, etc. as
necessary). An anticoagulant type bait would be used because 1) they are effective in very low
concentrations, 2) there is an antidote (vitamin K) to accidental poisoning, and 3) secondary hazards are
lower than for more acute toxicants (Witmer 1998). Diaphacione has no effect mo the crabs due to
different blood composition (Campbell 1989). The risk to birds of secondary exposure through
predation/scavenging of live /dead mice and rats containing rodenticide residues is low because field
personnel would routinely recover dead rats and mice and bury them in the ground during all control
operations.

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Numerous kill traps are available and many are species-specific, greatly reducing capture of non-target
species. Captured animals generally do not eat the bait once in the trap. If water is added to the trap, it is
usually spilled by the captured animal, which becomes very animated for brief periods before settling
down. When USDA/APHIS Wildlife Services Division field personnel arrive, the animal endures some
trauma when being prepared for euthanization. The field personnel would bury euthanized rats caught in
public use areas of the Park.

Sodium pentabarbatol is an excellent central nervous system agent. Once properly injected with a small
amount (average 2 cc/adult) in the heart, the animal falls into a deep sleep within 1 2 minutes and is
dead within 5 minutes. The drawbacks include stress on the animal, increased field time and high drug
costs.

A "squeeze box" can be used to hold an animal for purposes of administering an injection. Because wild,
aggressive omnivores cannot be safely placed into a "squeeze box" without first muzzling them, the
animal must receive the injection while inside the live trap. This requires opening the cage door and
quickly inserting a large cushion and pressing the animal and particularly its' sternum, into the cage floor.
When properly positioned, the heart is readily exposed for the lethal injection.

Another injecting alternative involves use of a "jab stick;" which consists of a syringe mounted to the end
of a small pole. Jab sticks are principally used to apply intramuscular injections and would be impractical
for an intracardiac injection. Other problems are the increased stress their use causes the animal,
problems injecting the desired location and insufficient dosage. In addition, the animal often moves when
the injection is taking place causing unnecessary injury and suffering.

Other means of destroying animals captured in live traps include drowning, clubbing, shooting, gassing
and suffocation. Drowning is considered inhumane because of the suffering caused before expiration, and
presents the problem of trap degradation. Clubbing is also considered inhumane and may allow maimed
animals to escape. Gas poisoning is problematic and inhumane because of the time requirement, which
may require up to 20 minutes, depending on the effectiveness of the apparatus. Suffocation is also
inhumane, time intensive and requires additional handling. Shooting remains the most humane, expedient
and cost effective treatment to dispatch a live-trapped animal, however, problems exist with shooting a
small animal and containing the projectile.

Kill Traps

Numerous kill traps are available and many are species-specific, greatly reducing capture of mntarget
species. Snap traps contained inside protective boxes have some applicability inside buildings after the
population is reduced. The advantages include target (species) selectivity, immediate and humane death
and lower labor costs. Some drawbacks include limits on trap placement, nontarget by-catch,
maiming/escape potential, and evasion by trap-shy individuals.

Both live and kill traps can be easily modified to reduce incidental by-catch. Because rats are relatively
small, their traps would also be small. In addition, if mice or mongooses were eliminated by a rat trap
that would be beneficial as they are also species targeted for control. Improvisations to eliminate the
capture of hermit crabs would be necessary (i.e. elevation of baits, bait site selection, etc. as necessary).
Capture of other nontarget species is unlikely.





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Bait Stations


An anticoagulant bait would be used because: 1) they are effective in very low concentrations, 2) there is
an antidote (vitamin K) to accidental poisoning, and 3) secondary hazards are lower than for more acute
toxicants (Witmer et. al. 1998). Bait stations would be distributed over the grid spaced at 50-foot
intervals near picnic areas, campgrounds and concession areas, and 150-foot intervals near the shoreline
and in the Park's upland areas. A pattern of trails would be established for bait placement and
maintenance. Trails which may be cut for upland bait-lines would be roped off and marked with 'Trail
Closed Signs" to caution visitors and residents from walking off the hiking trail and onto the bait-lines.
Trails would be hand cut with machete, but only the necessary amount of vegetation would be cut to
allow for the passage of one person.

Approximately two ounces of bait would be placed in each bait station. Bait stations would be affixed to
trees or the ground with cable ties, wires or stakes. This would prevent bait stations from moving either
in high winds or heavy rains, and reduce the chance of removal by a curious visitor. The stations are
closed and locked so that a small child cannot access the bait. All bait stations would be numbered
sequentially and labeled "NPS Rat Program Do Not Touch" in both English and Spanish.

Once initiated, the baiting operation would require a minimum of 6 months to complete, with monitoring
and maintenance indefinitely. Baiting would be the most intense during the dry season. After placement,
baits will be checked and replaced as needed. Initially this would be every day for the first weeks, but
would taper to about once per week after the rat population is reduced. Typically, baits are maintained for
weeks after consumption has virtually stopped to help assure most rats have been eliminated (Witmer et.
al. 1998).

Chemical/Poison

Several types of rodenticides are available and have been successfully used for the management or
eradication of commensal rodents. An anticoagulant type bait would be used because 1) they are
effective in very low concentrations, 2) there is an antidote (vitamin K) to accidental poisoning, and 3)
secondary hazards are lower than for more acute toxicants (Witmer et. al. 1998). Most rodenticides are
registered for use in or within 150 feet of man-made structures. Use of rodenticides at Virgin Islands
National Park would require authorization through a Section 24c of the Federal Insecticide, Fungicide and
Rodenticide Act (FIFRA). The numerous existing toxicants would not be described in this document, in
part because data are insufficient to support FIFRA registration. Thus, it is unrealistic to consider use of
any other rodenticide for this program.

Several chemicals were considered for use including brodifacoum and zinc phosphate, but diphacinone (J.
T. Eaton's Bait Blocks Rodenticide, EPA Reg. No. HI-970007 Appendix C) was selected due to the
considerable existing data to support registration, its excellent record in other similar control programs,
and low hazards to non-target species compared to more acute toxicants (Conry 1994). Diphacinone has
been used extensively for rodent control since the 1960's and for several years in other island situations.
There have been no reported cases of secondary poisoning for raptors and only a few cases of poisonings
in mammals. Diphacinone also has proven to be an excellent choice for mongoose control, an additional
goal of this program.

The only non-target species we can determine that might have very large exposure to bait is the hermit
crab. Dr. Earl Campbell with the USDA APHIS National Wildlife Research Center and other researchers
familiar with this use pattern reported the concern is primarily one of baiting efficiency and not non-target
hazards, as apparently the diaphacione has no effect on the crabs due to different blood composition

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(Campbell 1989). Efforts will be made to monitor and minimize this concem (i.e. elevation of baits, bait
site selection, etc as necessary). There are no listed species present expected to eat baits or dead rats or
dead mongooses.

Diphacinone has been used extensively and effectively for rodent control since the 1960's. Diphacinone is
an anticoagulant that depresses the synthesis of prothrombin, an essential clotting factor. Buck Island
Reef National Monument in St. Croix, U.S. Virgin Islands (NPS Buck Island Reef NM 1999) researched
methods to eradicate non-native rats from the Monument. In 1999, they were granted a Section 24c
permit under FIFRA, in cooperation with the Territorial Government of the U.S. Virgin Islands, to
administer diphacinone (Eaton's Bait Blocks Rodenticide with Fish Flavorizer). The rat eradication
program at Buck Island was very successful. All of the rats on the Island were killed. No rat tracks or
scats have been observed at sea turtle nesting beaches since the program was implemented. NPS is
continuing to monitor several transects to ensure that no rats return to the Island.

For a non-target species to be at risk of hemorrhaging, it would have to consume a minimum amount of
the anticoagulant. Before any symptoms of anticoagulant poisoning are measured, a threshold level
concentrated in the liver, must be reached. Symptoms include, but are not limited to, increased time to
clotting (prothrombin times (PT)) leading to hemorrhaging. A minimum amount of active ingredient
must be consumed, absorbed and bound in the liver. Then, a significant decrease in the production of
active clotting factors, resulting in an increased prothrombin time, must occur before an individual is
considered at risk of hemorrhaging. Thus, organisms are able to tolerate sub-lethal levels of
anticoagulants without displaying any symptoms of poisoning. Therefore, all animals are can tolerate
some level of anticoagulant rodenticide exposure without risk of hemorrhaging. The level of risk is
determined by the toxicity of the chemical and that individual's exposure. This analysis will focus on the
potential primary and secondary poisoning risks to the wildlife resources.

Secondary toxicity would require a predator to eat several poisoned prey before reaching the threshold
level to produce hemorrhaging. All the species of herptofauna living on St. John are primarily
insectivorous and are at a low risk of exposure to these rodenticides; the use of bait stations would
exclude most individuals from exposure. The pelagic and roosting seabirds are considered to be at a low
risk of primary poisoning because their foraging strategy is almost exclusively offshore. They are almost
exclusively carnivorous, preferring live marine prey. Brown Pelicans are not scavengers and will not eat
dead and poisoned rodents. The use of bait stations would exclude most of the landbirds that are either
granivorous or omnivorous from primary exposure risks. Although there are incidences of poisoning in
most island eradications, some impacted species recovered to population densities that were higher than
densities before rodenticide application due to removal of predators (Empson and Miskelly 1999;
Robertson et. al. 1999).

Some birds of prey, such as Red-tailed Hawk and American Kestrel, and scavengers are not at risk of
secondary exposure through predation/scavenging of live or dead mice and rats containing rodenticide
residues; because field personnel would routinely recover dead rats and mice and bury them in the ground
during all control operations. Birds of prey eat only living animals, while poisoned rodents would die in
their burrows and thus be out-of-sight for any potential scavenging of rodents killed by poison.
Therefore, it would be an extremely remote possibility that any birds of pey would ever locate and
consume enough poisoned rodents to produce hemorrhaging.






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Non-native Rat Action Plan


A Non-native Rat Action Plan is necessary with the following elements: problem identification; density
thresholds; enhanced food handling, storage and waste practices (including trash pickup schedules);
enhanced landscaping practices; written guidelines for visitors, NPS and concessions employees; and
routine removal and monitoring efforts. During periods with low moisture, rats become more aggressive
because their need for water increases. Also, when more food becomes available, their numbers increase
dramatically in a short time. Basic education, routine population reductions, enhanced sanitation and
basic monitoring will largely mitigate the rat problems throughout the development areas (where they are
found in highest densities). A successful program will stress the long-term and ongoing nature of the
solution. Too often similar problems are quickly arrested in the short-term, only to reoccur later when the
original actions are slowed or discontinued.

Ecological Research and Monitoring

The trap census method for determining relative rat population abundance will be adopted from Witmer,
Campbell and Boyd (1998). Live traps and bait stations will be maintained and trap censuses conducted
by USDA/APHIS Wildlife Services Division field personnel who will be working on the project through
an Interagency Agreement. Dead rats found in the public use areas of the Park would be recovered by the
field personnel and buried in the ground.

This is a technique for monitoring rat population abundance in selected areas, resulting in capture per unit
effort over time. Prior to baiting, trap censuses will be conducted every hour for three consecutive using a
mixture of peanut butter and rolled oats for bait. Snap traps will be placed along existing trails in areas
prior to initiating the reduction program at that particular site. Traps are secured to the side of a tree
about 10-20 inches above the ground surface with a trap placed every 50 feet along the trail. The
following data is collected from the trapped rats; sex, age class, reproductive condition, size, weight, and
overall condition (clean, healthy, malnourished, scarred, etc).

Trap censuses will be repeated quarterly to monitor population change during the baiting program. Trap
censuses will be continued along several established bait station trails. The locations of these trap census
areas will be determined after the bait stations trails are established.

Research efforts will concentrate on the natural history, movements, population dynamics, and impacts of
non-native rats on the Park ecosystem using volunteers, student interns or graduate students (as necessary
and available). Research relating to rats would provide information useful in refining control techniques.

Rodent-proof Construction

The sustained reduction program follows an Integrated Pest Management approach and includes adoption
of rodent-proof construction techniques and the application of those techniques in development and
maintenance of all Park and concessionaire facilities. An effective method of reducing rodent damage is
rodent-proof construction. Techniques apply both to new construction and modifying existing structures.
Rodent-proofing is a good investment. It is less expensive to design rodent-proof buildings than to add
rodent-proofing later (Timm and Bodman, 1984).

Information and Education

The sustained reduction program also includes public education and public service announcements
regarding the rats and their impacts on the Park's natural resources, as well as improved picnic and

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campground area trash management using animal-proof containers and rodent-proof construction
techniques. Public awareness regarding the benefits of the rat reduction program, therefore, would be
promoted whenever possible. Attempts would be made to work with community leaders, governmental
and non-governmental organizations to develop and disseminate information cn an ongoing basis. These
communication avenues will be maintained over time and should help to defuse situations before they
lead to problems.

Alternatives Considered but Dismissed from Detailed Study

Biological Control (Biocontrol). Biological controls are inappropriate in this situation. Biocontrol is the
use of species-specific control agents, typically diseases or insects from the host's range, to provide
effective control of a target pest. Use of biological controls can lead to unforeseen and unfavorable
circumstances, therefore, they were not considered for this application.


II.A.2. Alternative 1. No Action, Continue Current Level of Management

Under the No Action, Continue Current Level of Management alternative, non-native Norway and roof
rats would continue to flourish essentially unabated throughout Virgin Islands National Park. The
terrestrial habitat would continue to decline under their foraging and predatory activities. Species
protected under the Endangered Species Act would continue to be adversely affected, as non-native rats
would continue to depredate endangered sea turtles, Brown Pelicans and Least Tems. Non-native rats
would also continue to adversely impact visitor services and experience at concessions throughout the
Park. There would be no use of rodenticides, except for the continued localized baiting in Park buildings.
With no rodenticide application, the non-native rat population would not be controlled, and the number of
rats on the island would fluctuate within the annual cycle.

Under the No Action alternative, NPS would continue to animal-proof trash receptacles and dumpsters at
campgrounds, day use sites, concession areas, park overlooks, and employee housing areas and collect
trash on a regular basis. During the last year, Virgin Islands NP purchased and installed over 50 pre-
manufactured animal-proof trash containers (at a cost of about $75,000) at all Park sites except at the
major concession operations at Trunk Bay and Cinnamon Bay to collect both refuse and recyclables. In
fiscal year 2002, the NPS requested $30,000 in funding to purchase and install an additional 20 pre-
manufactured animal-proof trash containers at major concession operations (eight at Trunk Bay and
twelve at Cinnamon Bay) to collect both refuse and recyclables.


II.A.3. Alternative 2. Proposed Action Sustained Reduction

Under Alternative 2, the Proposed Action, the National Park Service, in cooperation with the U.S.
Department of Agriculture's Animal Plant Health Inspection Service / Wildlife Services Division would
conduct a site-specific non-native rat population reduction program using a combination of trapping,
rodenticide applications, and other cultural practices within Virgin Islands National Park. The goal would
be to reduce the non-native rat population in Virgin Islands National Park and to sustain a reduced
population. The proposed action to accomplish this goal consists of a three-phase approach:

Phase I Planning, Logistics, Consensus-Building

Essential elements of Phase I include the development of a basic Non-native Rat Action Plan and
educating concession operators and key NPS staff in implementing the plan using an Integrated Pest
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Management approach. This can only be accomplished through consensus-building efforts from each
group or partner involved and most importantly the food concessionaires. In addition, reductions in food,
harborage and building access are essential early steps.

A comprehensive inspection of every concession and NPS building by trained personnel and the
application of mechanical rodent proofing techniques to restrict access are necessary. The surrounding
areas would be inspected and treated with landscaping alterations aimed at reducing rat harborage at such
sites as Caneel, Trunk and Cinnamon. For example, vegetation must be removed and maintained from
within 18 inches of all structures, including trash receptacles, and brushy vegetation removed and
maintained from within 12 inches of the ground.

Trash collection procedures hcluding storage practices and removal schedules would be reviewed and
revised to ensure minimal food presence during the majority of time. Particular emphasis would be
placed on ensuring that virtually no food is available or accessible at night and especially outside any
concession structures. All trash receptacles would be retrofitted and therefore inaccessible to non-native
rats, cats and mongooses. The campground will issue and require the use of rodent-proof food storage
containers for all cottage, tent and bare site guests, as well as a brochure explaining the importance of not
feeding any wildlife and the integrated pest management approach in place at the Park.

Phase II Quick Reduction

For non-native Norway and roof rats, Phase II would consist of a initial single, large scale direct reduction
using bait stations with diphacinone or baited live traps throughout the Park. Follow-up trapping/census
would reduce populations by approximately 80% of what their current populations are estimated to be
through an initial snap-trap census. The trap census technique (Witmor, 1998) will be employed for this
estimate. Rat populations would be monitored and maintained at acceptable levels with continued
trapping and use of bait stations.

Phase III Monitoring A Sustained Reduction

Phase III is the ongoing monitoring and record-keeping portion essential to maintain the goal to sustain
the population reduction. General visual monitoring will be conducted quarterly in the evening to
ascertain relative rat populations within high visitor use areas. The numerous changes to reduce trash,
food and harborage in Phase I must be regularly monitored along with the rat population. Snap trap
surveys may also be used to verify potential rapid population increases, as personnel are available. The
consensus-building efforts that were necessary to accomplish Phase I must be ongoing, as new people
become involved and others leave.

The Park intends to work cooperatively with partners including concessionaires, residents, non-
government organizations (NGO's) and visitors. The Park will facilitate the development of a
comprehensive educational campaign with key NGO's and will disseminate the information through the
newspaper, radio and Internet. A brochure will be developed and disseminated through the Visitor Center
explaining the integrated pest management approach and the reasons why neither native nor non-native
wildlife must not be fed in the Park. The key areas of Phase III include monitoring, partnerships and
education, and these must be sustained over the long term.






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II.B. Non-native Cat Control Alternatives


II.B.1. Non-native Cat Control Techniques

This section describes techniques for non-native feral cat control. Non-native cat control methods are
outlined below. Remedies such as landscaping changes and others are discussed elsewhere on Pages 18
and 19. Please refer to II.A.1. Non-native Rat Control Techniques, for a more thorough description of
the mechanical, chemical and other cultural practices and information that applies equally to cats. This
section describes methods for an extensive, rapid and humane population reduction effort for cats. The
following control techniques are presented here for non-native feral cats.

Trap-Test-Alter-Vaccinate and Adopt Programs

The program is designed to trap 100% of the Park's feral cats, test for disease, surgically sterilize and
place for adoption disease-free animals. Collared or registered cats will be returned to their owner.
Uncollared cats will be taken to the St. John Animal Care Center (SJACC), where local veterinarians have
reducing their fees and services to test, sterilize and ear-clip the cats. Animals are chemically euthanized
by American Veterinary Medical Association (AVMA) approved methods if they test positive for either
Feline Immunodeficiency Virus or Feline Leukemia Virus. Through funding provided by the St. John
Audubon Society, the Park will help to ensure that animal tags are available to the public so they can
personally identify their cat as having a home. Both local veterinarians will tattoo the ear of a domestic
cat for a nominal anesthetic fee. Therefore, inadvertently trapped cats will be returned to their owner.

The SJACC will place every treated cat for adoption; meanwhile, many will be released to feeding
stations outside the Park. If a treated cat is captured within the park once or twice it will be returned to
SJACC. A third capture requires placement with the Humane Society of St. Thomas/St/ John. At that
facility the cat will be placed for adoption or destroyed.

Often used in the initial efforts to humanely reduce domestic cat colonies, cats are captured, tested and
treated for disease and sterilized. Placement facilities then operate to disperse the animals into homes.
When and if the adoption market saturates, the program must be discontinued. NPS believes homes can
be found for the estimated 15-30 feral cats due to the number of individuals who have contacted the Park
and expressed a desire to adopt or house captured cats.

One problem with this method is that most cats are not easily domesticated and few people want to
attempt to tame an aggressive adult cat, especially after the kitten is older than 6 months of age. The lives
of adopted cats would be far superior to the lives they had following abandonment in the Park; where
disease, starvation, territorial fights with other cats, and automobile collisions are standard. Free-roaming
cats typically live less than five years, whereas cats exclusively kept doors often live to 17 or more
years of age. Several individuals have expressed the desire to provide indefinite housing for cats that are
not domesticable.

Keep Cats Indoors Programs

To prevent cats from becoming predators and harming wildlife, the NPS would work closely with local
landholders and communities in an effort to stem the flow of non-native domestic cats into the Park by
promoting responsible cat ownership. NPS would support programs to neuter or spay adolescent cats,
register cats, and encourage owners to keep their cats indoors; and not to abandon unwanted animals in
the Park. NPS would work with the scientific, conservation and animal welfare communities to educate

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the public about the dangers free-roaming cats pose to human health, thirds and other native wildlife and
the difficult life of free-roaming cats.

Outdoor domestic cats, even otherwise well cared for cats, face an extraordinary array of dangers.
According to the Humane Society of the United States, free-roaming cats typically live less than five
years, whereas cats exclusively kept indoors often live to 17 or more years of age. The American Bird
Conservancy's Cats Indoors Campaign is supported by thousands of individuals and organizations in the
conservation, animal welfare, wildlife rehabilitation, and veterinary communities (The Wildlife Society,
Number 307, 2001).

Unaltered outdoor cats are the major source of the cat overpopulation problem, causing millions of
unwanted cats to be euthanized at animal shelters each year. Humane Societies and animal care and
control agencies struggle to rescue, treat, feed, and house stray and unwanted cats. Kittens can be safely
spayed or neutered as early as eight weeks of age with substantial health and behavioral benefits. Without
the biological urge to roam and mate, spayed or neutered cats live more contentedly indoors.

Alternatives Considered but Dismissed from Detailed Study

Trap-Test-Alter-Vaccinate and Release (TTAVR) Programs. Non-native domestic cat populations
pose problems for native fauna worldwide. In areas where eradication is unfeasible, the TTAVR system
is one alternative (Patronek 1997). TTAVR programs have become more common in urban settings,
especially in affluent communities of large metropolitan cities and less common in rural areas. Few
studies have been conducted to compare TTAVR with other alternatives. The program is designed to trap
100% of the animals, test for disease, surgically sterilize and release disease-free animals. Diseased
animals are chemically euthanized. The released cats are maintained and fed in carefully supervised
colonies, where the ultimate goal is colony elimination through attrition.

Few TTAVR programs have been carried out in rural areas with several cat colonies, and none reported
colony elimination. The major problems are new introductions, trap-shy individuals and continued native
fauna depredation even with adequate feeding. As noted elsewhere for mongooses, a mistaken or
malicious abandonment of one pregnant cat can initiate the formation of an additional colony. Moreover,
because supplemental feeding of treated cats is necessary to humanely conduct the program, many non-
target species, including non-native rats and mongooses, are also fed (Appendix D).

A recent study by Dan Castillo at the Department of Environmental Studies at Florida Intemational
University (2001), contradicts widely-held beliefs by cat colony proponents that well-fed cats do not kill
wildlife, that cats are territorial and will prevent more cats from joining the colony, and that cat colonies
decline in size over time.

Two cat colonies in Miami-Dade County parks were observed for 13 months and, contrary to previous
assumptions, it was found that almost every month new cats joined the colonies while other cats
disappeared. The colonies acted as dumping grounds for unwanted cats, despite state and county laws
making this illegal. Despite attempts by volunteers to have the cats spayed or neutered, intact cats were
observed, as were pregnant cats and newborn kittens.

Although well fed, cats at both locations were observed chasing, stalking and killing birds and other
animals. Aggressive interactions among the cats were few and did not limit cat access to food or the
colonies. Cat feeders placed large amounts of food throughout the parks that then attracted other animals
such as raccoons, foxes, skunks and stray dogs.


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According to Castillo, "Managed cat colonies are not the solution to cat overpopulation problems. My
findings demonstrate that the establishment of cat colonies on public lands encourages cat abandonment
and is harmful to native wildlife. Cat colonies do not decline over time they just perpetuate
themselves."

Linda Winter, Director of Cats Indoors! for American Bird Conservancy, a non-profit conservation group,
stated, "Mr. Castillo's study confirms what other studies have shown that cat colonies cannot be
managed and do not belong in parks. Solutions to the stray cat overpopulation must also protect birds and
other wildlife."

Very large problems with feeding cat colonies include feeding and proliferation of non-target species,
promoting people to abandon unwanted cats (and other animals) at the feeding stations and many fed cats
will continue to depredate other fauna, contract or spread disease. Moreover, some may leave the feeding
station and re-enter protected areas, such as a nearby National Park. However, because the cat
populations living within the Park are relatively small, and this program has very large community
support, we have reached a compromise for this program. This program has operated outside the Park for
almost ten years, and our public relations will be considerable because we will give cats several chances
to survive outside the Park, before transporting them to the Humane Society of St. Thomas/St. John.


II.B.2. Alternative 3. No Action, Continue Current Level of Management

Under the No Action, Continue Current Level of Management alternative, non-native domestic cat prides
would exist unabated throughout Virgin Islands National Park. The terrestrial habitat would continue to
decline under their foraging and predatory activities as non-native cats would continue to depredate
endangered Brown Pelicans, Least Terns, and Hawksbill and Leatherback sea turtle hatchlings.

The no action alternative would result in occasional non-native cat removal efforts by Park and
concessions personnel as a stopgap measure when local populations become excessively large.
Simultaneously, employees of the Park, concessionaires, locals and visitors, would continue both periodic
and organized feeding throughout the Park. Some locations have been the target of organized feeding
efforts for several years. These areas include Annaberg and Francis, Maho, Cinnamon, Trunk,
Hawksnest, Caneel, Saltpond and Lameshur bays. Cats would continue to be regularly abandoned in the
Park. This illicit feeding contributes directly to the growth of other non-native animal populations in the
Park including mongoose, mice, chickens, and to a lesser degree rats.

Under the No Action alternative, NPS would continue to animal-proof trash receptacles and dumpsters at
campgrounds, day use sites, concession areas, park overlooks, and employee housing areas. During the
last year, Virgin Islands NP has purchased and installed over 50 pre-manufactured animal-proof trash
containers (at a cost of about $75,000) at all Park sites except at the major concession operations at Trunk
Bay and Cinnamon Bay to collect both refuse and recyclables. In fiscal year 2002, the NPS requested
$30,000 in funding to purchase and install an additional 20 pre-manufactured animal-proof trash
containers at major concession operations (eight at Trunk Bay and twelve at Cinnamon Bay) to collect
both refuse and recyclables.







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II.B.3. Alternative 4. Proposed Action Sustained Reduction

Under Alternative 4, the Proposed Action, the National Park Service, in cooperation with the U.S.
Department of Agriculture's Animal Plant Health Inspection Service / Wildlife Services Division would
conduct a site-specific non-native domestic cat population reduction program using live trapping followed
by adoption, and other cultural practices within Virgin Islands National Park. The goal would be to
reduce and sustain a cat population of zero or near zero throughout the Park. The proposed action to
accomplish this goal consists of a three-phase approach:

Phase I Planning, Consensus-Building & Education

Essential elements of Phase I include the development of a basic Non-native Cat Action Plan and
educating concession operators and key NPS staff in implementing the plan using an Integrated Pest
Management approach. This is accomplished through consensus-building efforts with each concerned
group or partner. Particular involvement, support and consensus-building efforts would be solicited from
the following non-governmental organizations: St. John Animal Care Center, Humane Society of St.
Thomas/St. John, St. John Community Foundation, Audubon Society, and the Environmental Association
of St. Thomas/St. John. The mutual goals will seek to develop, implement and disseminate
comprehensive information to a local audience on a continual basis. Local educational seminars would
be planned in conjunction with other community events (e.g. Earth Day); to help educate the public about
the problems associated with feral cats.

To prevent cats from becoming predators and harming wildlife, the NPS would work closely with local
landholders and community groups to stem the flow of non-native domestic cats into the Park by
promoting responsible cat ownership. NPS would support programs to neuter or spay cats before reaching
reproductive age, register cats, encourage owners to keep their cats indoors, and not to release unwanted
animals in Park. NPS would work with the scientific, conservation and animal welfare communities to
educate the public about the dangers free-roaming cats pose to human health, birds and other native
wildlife. The misery and disadvantaged life and hazards to free-roaming cats would be included.

Trash collection procedures, including storage practices and removal schedules that were revised for non-
native rats would assist with non-native cat reduction efforts. Trash receptacles allowing non-native rats,
cats or mongooses would be retrofitted to exclude them. The campground will issue and require the use
of rodent-proof food storage containers for all cottage, tent and bare site guests, as well as a brochure
explaining the importance of not feeding any wildlife and the integrated pest management approach in
place at the Park.

Phase II Quick Population Reduction

For non-native cats, Phase II consists of an initial, single, large-scale direct reduction using live traps
followed by adoption where possible. The Park will assist the St. John Audubon Society to register
domestic cats using free ear-tags and break-away collars. A St. John veterinarian has offered to tattoo
ears of domestic cats for the cost of anesthesia. Any collared or tattooed animals will be returned to their
owners. Unmarked animals will be provided to the St John Animal Care Center (SJACC). Cats testing
positive for Feline Immunodeficiency Virus or Feline Leukemia Virus will be destroyed by American
Veterinary Medical Association (AVMA) approved methods. Veterinarians working for or subsidized by
the SJACC will sterilize cats testing negative for those viral diseases and clip their left ear. These cats
will be placed for adoption or released to a feeding station outside the Park boundary. Cats that are
recaptured twice after they were treated and released by SJACC will be given to the Humane Society of
St. Thomas and St. John.

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Follow-up census/trapping efforts would attempt to remove approximately 100% of the 15-30 existing
non-native cats at such sites as Trunk, Cinnamon and Francis Bays and Annaberg. Initially, efforts would
be made with interested individuals to remove cats from throughout the Park prior to trapping. Traps
would be checked at no greater than 6-hour intervals so cats are subjected to minimal stress.

Phase III Monitoring the Sustained Reduction

Phase III is the ongoing monitoring and record-keeping portion essential to maintain the goal to sustain
the reduction. The consensus building efforts that were necessary to accomplish Phase I must be ongoing,
as key positions and personnel change. Work effectively and cooperatively with NGO partnerships to
including concessionaires, residents and visitors. Develop a comprehensive educational campaign and
disseminate information continually. A brochure will be developed and disseminated through the Visitor
Center explaining the integrated pest management approach and the reasons why neither native nor non-
native wildlife must not be fed in the Park.

The consensus-building efforts that were necessary to accomplish Phase I must be ongoing, as new people
become involved and others leave. The Park must sustain the partnerships with concessionaires, residents,
and especially the SJACC and other NGO's. The Park would facilitate the development of a
comprehensive educational campaign with key NGO's, and would disseminate the information through
the newspaper, radio, Intemet and public forum. The key areas of Phase III include monitoring,
partnerships and education, and these must be sustained over the long run.



II.C. Non-native Mongoose Control Alternatives

II.C.1. Non-native Mongoose Control Techniques

This section describes the primary mechanical and chemical methodologies, and other cultural practices
for non-native mongoose control. Remedies such as rodent-proof construction techniques, landscaping
changes and others are discussed elsewhere on Pages 18 and 19. Mongoose control methods are outlined
below and include: mechanical live trap and euthanization; live traps; and chemical/poison. Please refer
to II.A. 1. Non-native Rat Control Techniques, for a thorough description of the mechanical, chemical and
other cultural practices and information which applies equally to mongooses.

This section describes methods for an extensive and rapid population reduction effort for non-native
mongooses.

Mechanical Live Trap and Euthanization

Captured mongooses must be killed because to relocate them would only transfer the problem elsewhere.
Extensive live traps are placed along designated trap lines transectss) and baited with chicken or sardines.
Measures are taken to reduce non-target captures of crabs, birds, etc. Numerous live traps are available
and many are species-specific, greatly reducing capture of non-target species. Sodium pentabarbatol is
an excellent central nervous system agent that will be used for euthanization. Once properly injected with
a small amount (average 2 cc/adult) in the heart, the animal falls into a deep sleep within 1 2 minutes
and dies within 5 minutes. Carbon dioxide gas or other American Veterinary Medical Association
(AVMA) approved methods would also be used for euthanization of mongooses.



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Live Traps


The NPS would use live traps baited with chicken or sardines to capture mongooses. Numerous live traps
are available and many are relatively species-specific, greatly reducing capture of non-target species.
Live traps can be easily modified to reduce incidental by-catch. Efforts will be made to monitor and
minimize this concern (i.e. elevation of traps, trap site selection, etc. as necessary).

Chemical/Poison

Sodium pentabarbatol is an excellent central nervous system agent that will be used for management of
carnivores, such as mongooses (euthanization). Carbon dioxide gas or other American Veterinary
Medical Association (AVMA) approved methods may also be used to euthanize mongooses.


II.C.2. Alternative 5. No Action, Continue Current Level of Management

Under the No Action, Continue Current Level of Management alternative, non-native West Indian
mongooses would continue to flourish essentially unabated throughout Virgin Islands National Park. The
terrestrial habitat would continue to decline under their foraging and predatory activities as mongooses
would continue to depredate endangered Hawksbill and Leatherback sea turtles, Brown Pelicans and
Least Tems, and the threatened Roseate Tems (NPS Management Policies 2001, Chapter 4, Page 11).
NPS would fail to comply with the NPS Organic Act (1916) requiring the protection of native flora and
fauna for future generations. Mongooses would also continue to adversely impact visitor services and
experiences at concessions throughout the Park. There would continue to be only very localized trapping
in Park buildings and campgrounds. Without widespread trapping, the mongoose population would not
be controlled, and the number of mongoose on the island would fluctuate within the annual cycle.

Under the No Action alternative, NPS would continue to animal-proof trash receptacles and dumpsters at
campgrounds, day use sites, concession areas, park overlooks, and employee housing areas. During the
last year, Virgin Islands NP has purchased and installed over 50 pre-manufactured animal-proof trash
containers (at a cost of about $75,000) at all Park sites except at the major concession operations at Trunk
Bay and Cinnamon Bay to collect both refuse and recyclables. In fiscal year 2002, the NPS requested
$30,000 in funding to purchase and install an additional 20 pre-manufactured animal-proof trash
containers at major concession operations (eight at Trunk Bay and twelve at Cinnamon Bay) to collect
both refuse and recyclables.


II.C.3. Alternative 6. Proposed Action Sustained Reduction

Under Alternative 6, the Proposed Action, the National Park Service, in cooperation with the U.S.
Department of Agriculture's Animal Plant Health Inspection Service / Wildlife Services Division would
conduct a site-specific non-native mongoose population reduction program using live traps baited with
chicken or sardines, and other cultural practices within Virgin Islands National Park. The goal would be
to reduce the mongoose population to approximately 80% of the current population at key population
centers throughout the Park.

The proposed action to accomplish this goal consists of a three-phase approach:



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Phase I Planning, Consensus-Building & Education


Phase I Essential elements of Phase I include the development of a basic Non-native Mongoose Action
Plan and educating concession operators and key NPS staff in implementing the plan using an Integrated
Pest Management approach. This is accomplished through consensus-building efforts with the Park,
concessionaires, and to a lesser extent local NGO's.

Trash collection procedures including storage practices and removal schedules that were revised for non-
native rats would assist with non-native mongoose reduction efforts. Trash receptacles would be
retrofitted to be inaccessible to non-native rats, cats or mongooses. The campground will issue and
require the use of rodent-proof food storage containers for all cottage, tent and bare site guests, as well as
a brochure explaining the importance of not feeding any wildlife and the integrated pest management
approach in place at the Park.

Phase II Quick Population Reduction

For non-native mongooses, Phase II would consist of a single, large scale direct reduction using live traps
baited with chicken or sardines at selected sites throughout the Park,. Follow-up census/trapping would
reduce populations by approximately 80% of what their current populations are estimated to be. This
approximation is based on survey estimates from Nellis and Evererd (1983), who found intensive trapping
over the short-term yielded about 80% of the local mongoose population to an acceptable level. Captured
mongooses will be humanely euthanized using sodium pentabarbatol or other AVMA approved methods.

Phase III Monitoring the Sustained Reduction

Phase III is the ongoing monitoring and record-keeping portion essential to maintain the goal to sustain
the reduction. General visual monitoring will be conducted quarterly in the daytime to ascertain relative
populations within high visitor use areas. An annual project to live-trap/euthanize may be considered at
specific sea turtle nesting beaches if personnel are available. The numerous changes to reduce trash and
food in Phase I must be regularly monitored along with the mongoose population. Basic, accurate record
keeping is essential for monitoring all aspects of this project.

The consensus-building efforts that were necessary to accomplish Phase I must be ongoing, as new people
become involved and others leave. The Park must sustain the partnerships especially with concessionaires
and local NGO's, and work cooperatively with residents and visitors. The Park will facilitate the
development of a comprehensive educational campaign with key NGO's and will disseminate the
information through the newspaper, radio, Internet and public forum. A brochure will be developed and
disseminated through the Visitor Center explaining the integrated pest management approach and the
reasons why neither native nor non-native wildlife must not be fed in the Park. The key areas of Phase III
include monitoring, partnerships and education, and these must be sustained over the long term.












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III. CHAPTER III. AFFECTED ENVIRONMENT


III.A. NATURAL RESOURCES

This section of the Environmental Assessment describes the current status of baseline information from
inventories, monitoring and research projects. NPS-77, "Standards for Natural Resource Inventory and
Monitoring", and the 1997 Inventory and Monitoring Implementation Plan by the Biological Resources
Division, USGS were also used as sources of information. The description of the affected environment is
not meant to a complete description of the program area. Rather, it is intended to portray the significant
conditions and trends of the resources that may be affected by the proposed program or its alternatives.

Setting
Virgin Islands National Park is located near the Tropic of Cancer in a group of small islands known as the
Lesser Antilles that separate the Caribbean Sea from the Atlantic Ocean. The most northwesterly of this
clustered island chain are the Virgin Islands of the United States and Great Britain, and approximately
113 kilometers (70 miles) to the west, the U. S. Commonwealth of Puerto Rico. The U.S. Virgin Islands,
made up of three main islands and 57 smaller, mostly uninhabited islands and cays, are found near the
crossing of 18 degrees north latitude and 64.5 degrees west longitude. The island of St. John (52 square
kilometers or 20 square miles) is the smallest and least developed of the three main U.S. owned Virgin
Islands. St. Croix (218 square kilometers or 84 square miles) lies approximately 64 kilometers (40 miles)
to the south of St. John, and St. Thomas (83 square kilometers or 32 square miles), lies about 4 kilometers
(2.5 miles) to the west.

Virgin Islands National Park comprises over half (2,816 hectares or approximately 10 square miles) of the
island of St. John. Established in 1956, the Park was expanded in 1962 to encompass 2, 287 hectares (8.7
square miles) of the surrounding waters. Of the NPS land on St. John, either private interests or the
Virgin Islands government owns three square miles. In 1978, Congress authorized the addition of
approximately 135 acres on Hassel Island in the Charlotte Amalie Harbor, St. Thomas to the Park. The
NPS has acquired most of the land on Hassel Island and has limited first right to match any offers on most
of the remaining private properties. The Virgin Islands government also owns lands on Hassel Island.
Also, on St. Thomas, approximately 15 acres in the Red Hook area are under Park jurisdiction and, until
recently, served as the Park's administrative headquarters.

Because of its internationally significant natural resources, Virgin Islands National Park was designated
an international biosphere reserve in 1976 and is one of the few biosphere reserves that has both marine
and terrestrial resources. The Park was included in the United Nation's Biosphere Reserve System as a
representative example of Lesser Antillean cultural and natural ecosystems.

Virgin Islands National Park contains examples of most tropical Atlantic terrestrial, coastal and marine
ecosystems. These include various examples of subtropical dry to moist forest, salt ponds, beaches,
mangroves, seagrass beds, coral reefs and algal plains. Terrestrial topography iB quite dramatic with
average slopes being 30 percent. The highest mountain peak plunges sharply to the sea over a distance of
three-quarters of a mile. Rock petroglyphs, middens and three settlements are several of the remains of
prehistoric cultures found to date. European settlement patterns and plantations systems significantly
altered St. John's biology and ecology removing native forests, building structures, terraces, rock walls
and roads, and importing vegetation and mammals. The plantation settlements took advantage of the
labor of African slaves. The last four decades have brought considerable change on St. John through the
development of vehicular transportation and roads, resorts, and other tourist facilities.

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In terms of visitor attractions, scenery and beaches are probably the most significant features of Virgin
Islands National Park. However, there are an estimated 250 historic structures within the Park, most of
them remnants of the Danish sugar plantation era, which are increasingly popular with tourists. Over the
past ten years, visitation to the Park has averaged approximately 942,800 persons annually.

Wetlands and Floodplains
Several guts or gullies have been known to have permanent pools of freshwater, some of which still
contain small populations of several species of shrimp and fish that were once a delicacy among local
residents. Guinea and Fish Bay guts still have populations of shrimp (Macrobrachyum sp., Atya sp. And
Xiphocaris sp.) and fish (one or two species of gobies and Mountain Mullet (Agonostomus monticola)).
Very little is known about these populations or their dynamics. Populations are undoubtedly greatly
reduced due to upstream discharges from commercial activities in the Susannaberg area (e.g. Moses'
Laundromat, Majestic Construction, etc.).

The pattern of rainfall and soil type is critical to recharge of streams or aquifers. Brief showers do not
significantly add to recharge. To create streamflow, 13 to 25 millimeters (2 to 4 inches) in a single
rainfall is necessary with a resultant 20-75% surface runoff flow.

Two intermittent streams, Guinea Gut and Fish Bay/Battery Gut, are both outside the park on the south
shore. Other smaller intermittent streams and many watercourses carry storm runoff for a short time after
heavy rainstorms transporting sediment to the sea. In most cases, the streambed and adjacent floodplain
restabilize over the years. If changes are made to the cross section, grade, plane or profile of the stream
or adjacent flood plain, sediment loss occurs and restabilization must take place. In most cases,
construction and changes in land use can be a major disruptive event increasing erosion and sediment
transport.

Mangrove habitats are the equivalent of salt marshes up north. They mostly occur as a coastal fringe of
red mangroves just seaward of terrestrial uplands but can also be found as basin forests at the base of
large watersheds. Mangrove shorelines make up a little more than 2% of the shoreline and are found in
protected bays: Cruz Bay, Mary's Creek, Haulover Bay, Newfound Bay, Hurricane Hole, Coral Harbor
and Fish Bay. Hurricane Hole may be the most pristine of the remnant mangrove habitats remaining in
the USVI (over 50 percent of all mangroves in the USVI have been destroyed during the past 50 years).
Mangroves are an important interface between terrestrial processes and marine habitats. They filter
sediment from upland runoff, thus maintaining water quality. They produce and export nutrients used by
other marine ecosystems. They provide a vitally important nursery habitat in their submerged prop roots
for many species of coral reef fish. Many species of birds nest or roost in mangroves where they are safe
from predators. The mudflats that form behind mangroves support populations of the large gray land crab
(Cardisoma guanhumii).

Salt ponds are shallow, saline ponds usually found at the base of valley drainage systems. They form as
reefs grow from two rocky points of a bay, eventually meeting in the middle and forming a berm created
by storm wave tossed coral rubble. This berm isolates the pond from the sea and usually becomes
colonized by mangroves and other salt tolerant species. Salt ponds are very effective upland sediment
traps, thus maintaining water quality in adjacent marine waters. Ponds are important habitat for many
species of shorebirds, bats and waterfowl where they feed on insects and invertebrates living in the pond
and nest in the fringing mangrove vegetation. Drastic fluctuations in salinity, temperature turbidity and
levels of oxygen and hydrogen sulfide make life in a salt pond a challenge for all but a few adaptable
species. Salt ponds also have many traditional uses such as soaking for medicinal purposes and collecting
salt for cooking. The salt deposits as the pond dries up during the dry season. The animal and plant life
associated with this ecosystem have not been well studied and the ecology of salt ponds is only partly

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understood. There are five salt ponds larger than 2 acres in size on St. John. The largest is on the south
shore behind Salt Pond Bay.

Terrestrial Vegetation
Large portions of the original forests of St. John were cleared for plantations during the late 1700s and
early 1800s. Many, if not most, of the tropical hardwood trees found here were harvested and sent to
Europe for furniture, boat and mast construction. This intensive modification of the forest distribution
and structure changed the hydrologic regime that was present on St. John. The island became drier as
vegetative cover was removed or modified. Evidence from relict streambeds indicates that St. John may
have had perennial streams that are no longer in existence. Ultimately, forest destruction has affected over
90% of the island. The present vegetation exhibits differing degrees of revegetation, ranging from
recently disturbed to late-secondary successional forests, which may be as old as 100 years. Eleven
vegetation types have been mapped, including: mangroves, salt flats, pasture, upland moist forest, gallery
moist forest, basin moist forest, dry evergreen forest, dry thicket and scrub, thom and cactus, disturbed
vegetation, and rock and coastal hedge. About 63% of the island is in the dry evergreen forest category
and 17% in the combined moist forest category. The upland moist forest contains some virgin stands
with minimal exotic floral species. The tallest trees on the island grow along the banks of the intermittent
streambeds.

Presently, the greatest threats to forest regeneration are human development and growing populations of
non-native hogs, goats and donkeys. Goats and donkeys alter forest composition by selectively feeding on
palatable species and distributing the seeds of exotic species through their feces. Hogs destroy vegetation
through rooting up of plants. Despite disturbance by non-native animals and construction, Park lands
continue to be a valuable refuge for native plant species. To date, 747 species of vascular plants have been
identified from St. John, of which 642 (86%) are native tb the island. The species are found in 117
families, of which 12 are introduced. Almost all species (99.7%) on St. John are found on other islands
within the Virgin Islands. Two species are endemic to St. John (Eugenia earhartii and Machaonia
woodburyana) and six others are endemic to the Virgin Islands. Another 25 species are endemic to the
Puerto Rico platform. Many voucher specimens and representatives of common plants have been
collected by premier botanists and placed in the Park herbarium collection, creating an extensive
collection of most species on the island. As they conduct monitoring and inventories, botanists continue
to identify new species. For example, Pedro Acevedo-Rodriguez of the Smithsonian Institute discovered
three species new to St. John in 1992.

Native Animals
The only mammal native to St. John are bats. Three of the six native species of bats are protected under
the V.I. Endangered and Indigenous Species Act of 1990 (Act No. 5665). Some bat species are important
pollinators of many floral species on the island as well as important seed dispersal agents for many
species of fruit bearing trees and shrubs. Other species of bats consume vast quantities of insects,
including mosquitoes. Fish-eating bats are also present. It has been noted that bat abundance at night on
St. John may exceed bird abundance during the day. Except for a short study using ultrasonic surveys to
detect bats, little is known of bat abundance, locations of roosting matemity colonies or threats to bats on
St. John.

Recent museum analysis of materials excavated from the Cinnamon Bay archeological dig during 1998
has yielded some startling discoveries. The remains of at least four extinct animals have been identified,
including the Caribbean Monk Seal (Vonachus tropicalis), Puerto Rican Shrew (Nesophontes, sp.), a
flightless rail and others. At least six other species have been identified which have been extirpated from
the Virgin Islands. This dig has revealed considerable information about faunal assemblages cn St. John
before European colonization and demonstrating that the Taino Indians lived a very different natural

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world from what we find today. These animals were apparently important food sources for these Native
American Indians. These Indians may have brought some species such as the Green Iguana (Iguana
iguana) and the Red-Foot Tortoise (Geochelone carbonaria) to the Virgin Islands from South America as
food sources.

Avifaunas are abundant and varied. The latest National Park Checklist of Birds on St. John includes 170
species in 17 families. St. John is an overwintering area for migratory warblers using the eastern flyway.
Fragmentation of habitat has been suggested for reducing populations of over-wintering warblers. More
recent research from 62 permanently marked survey points in moist forest and dry woodland on St. John
suggests that the reduction in numbers of overwintering warblers is due primarily to reduced numbers of
one species (Northem Parula) and possible reductions in breeding populations along the southeastern
United States from North Carolina to northem Florida. Birds are probably the best-studied group of
terrestrial animals in the Park. Continued surveys are necessary to determine trends in populations of
resident and migratory species.

The terrestrial reptiles and amphibians on St. John are quite varied. There are three native species of Tree
Frogs (Eleutherodactylus lentus, E. antillensis and E. cochranae) and one introduced species, the Cuban
Tree Frog (Osteopilus septrionalis), one introduced Marine Toad (Bufo marinus), two Geckos
(Hemidactylus mabouia and Sphaerodactylus macrolepis), three species of Anolis Lizards (4nolis
stratulus, A. cristatellus and A. pulchellus), the Red-foot Tortoise (introduced), Green Iguana
(introduced), Ground Lizard (4meiva exsul), Legless Lizard (Amphisbaena fenestrata), Worm or Blind
Snake (Typhlops richardii), atype of Garter Snake (Arrhyton exiguus), the Puerto Rican Racer (Alsophis
portoricensis) and the Slipperyback Skink (\h11,,i y mabouya). Herpetological populations on St. John
have not been adequately inventoried or monitored. Species that occur on nearby islands may also occur
here but have not been observed and documented.

Catherine Curry made a checklist from insect species in the Park museum collection in 1970 when ten
families were represented and 52 species identified (Curry 1970). William Muchmore (1987) studied
terrestrial invertebrates in 1987 and made a collection of common representative insects for the Park. Two
hundred and thirty-two species representing 124 families were identified. Arachnida (scorpions,
pseudoscorpions, harvestmen, and spiders) made up the largest order. Jeremiah Trimble has identified
thirteen species of dragonflies and damselflies (Order Odonata) in VINP (Trimble J., IAR, 1997). Michael
Ivie (1983 and 1984) has been studying beetles (Coleoptera) in the Virgin Islands for several years.
Before he started, approximately 75 species of beetles had been described for the VI. He has now
documented over 1500 species (several new species) and expects to find over 2000. Most of these species
may be found in VINP, but will only be documented through further studies. Additional inventories
covering a greater number of families are needed to more fully document the species and distributions of
insects within VINP.

Endangered/Threatened Species
The Endangered Species Act (PL 93-205) requires that federal agencies protect all listed species and
habitats. Twelve federally listed endangered and threatened species have been observed in the Park. Five
species of whales, as well as several dolphin species, may migrate through the Park. The endangered
West Indian Manatee had been recorded as being very rare around St. John, although it has been recently
recorded (ca. 1990) from West End, Tortola. These listed species, which include six marine mammals,
five birds, three reptiles (sea turtles) and two plants.

Five federally listed threatened or endangered bird species have been identified. The federally
endangered Brown Pelican nests, feeds and roosts both adjacent to and within National Park boundaries.
The U.S. Fish and Wildlife Service is evaluating nesting success in considering this species for delisting.

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The federally endangered Peregrine Falcon is a rare winter migrant. The federally threatened Roseate
Tern and endangered Least Tem are summer residents that have both been observed nesting within the
Park in recent years (1997 and 1999, respectively). Piping Plover are a very rare summer migrant.

Two of the federally listed sea turtles are commonly found in Park waters. The Hawksbill Sea Turtle
requires coral reefs for food and refuge. Peak nesting season on Park beaches is from July through
November, although nesting activity may take place any month of the year. While Green Sea Turtles feed
in seagrass beds in Park waters, they are infrequent nesters on St. John beaches.

The federally endangered Virgin Islands Tree Boa (Epicrates monensis granti) has never been observed
on St. John although it occurs on the east end of St. Thomas and on Tortola, BVI. This species could
conceivably exist on St. John.

All federally and territorially listed species require some level of protection and monitoring. Direct
impacts on federal endangered species by non-native species include the rooting of C. thomasiana by
non-native hogs and depredation of sea turtle nests and eggs by the small West Indian Mongoose
(Herpestes auropunctatus). Non-native goats and donkeys may be having an impact on many territorial
endangered species of plants. Sea turtles are periodically struck and killed by boats speeding through Park
waters. Nesting frequencies have decreased on many beaches due to adjacent upland development that
results in people, lights and dogs, all of which deter turtles from using particular beaches.

While considerable information exists on seasonality of nesting for sea turtles using VINP beaches, no
rigorous studies of nesting numbers and frequencies on all VINP beaches has been carried out since the
early 1980's. While the distribution of endangered plants is relatively well known, the extent of threats to
the species is speculative.

Introduced Animals and Plants
With the exception of bats, the VINP is presently inhabited by numerous species of non-native mammals
that have produced severe impacts on many indigenous species of plants and animals and threats to visitor
safety. Non-native mammals include the white-tail deer, donkey, hogs, goats, sheep, cows, European
boar, Indian mongoose, rats and cats. With the possible exception of the deer, increasing populations of
these species are seriously affecting native species of plants and animals. Hogs and European boar are
seriously threatening the sole, small remaining populations of the endangered St. Thomas Lidflower
(CoII'yh lvIoilL thomasianum) and Solanum conocarpum, which has been proposed for listing. Cats have
and continue to threaten populations of reptiles and ground and shrub nesting birds as well as providing
vectors for transmission of parasites and diseases to humans. Mongoose have devastated reptile
populations, some bird populations and continue to depredate the nests of the endangered hawksbill sea
turtle (Coblentz, 1983).

Donkeys destabilize steep slopes through maintenance of trails and this results in erosion and impact to
coral reefs and seagrass beds. They also affect plant community composition, distribution and succession
through selective feeding and dispersal of exotic plant species. Goatherds are capable of denuding large
areas of land cf all vegetation, including trees (through bark stripping) and cactus. The VINP represents
possibly the largest and best example of dry tropical forest remaining in the Caribbean and many of these
exotic species are having a serious impact on its health and sustainability.

Some of these species also threaten visitor experience and safety. Donkeys continue to enter campsites
and destroy tents and camping equipment in their efforts to locate food items. Visitors have been bitten
and threatened by some donkeys. Traffic safety becomes an issue when visitors stop to look at or


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photograph donkeys on the road, thus impeding traffic and causing accidents. Diseases ("creeping
eruption") that have been transmitted by cats have recently affected numerous visitors.

While many of the introduced species are recognized as having on our indigenous species of plants and
animals, these impacts have never been quantified. Quantification would enable NPS to realistically
prioritize species in terms of threats and guide us in the development of management measures to address
the threats.


III.B. NATURAL RESOURCE THREATS

This section of the Environmental Assessment summarizes the condition of the natural resources. It
addresses the nature and severity of major threats to the natural resources and impacts that have the
potential to degrade those resources.

Land Use and Boundary Issues
Approximately 53% of the island is federal land. The Park owns 2939 hectares (7,259 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.

There are currently no NPS restrictions on the type of development that can occur on non-federal. Local
zoning or Coastal Zone Management Act (CZM) protection has often been inadequate because it is not
rigidly enforced. Virgin Islands National Park participates in CZM or any permit review for construction
or modification of land within or adjacent to Park boundaries. The Resource Management Division has
established mechanisms for the Park to be 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 watch for potential development. Due to lack of eminent domain authority, the
Park has to compete for NPS acquisition funds and/or must work closely with groups like the Friends of
Virgin Islands National Park and Trust for Public Lands who can either purchase land and hold it until
Park funds are available or purchase and donate land to the Park.

Development of private inholdings and land adjacent to the Park boundary and pressure to re-open and/or
pave old Danish cart roads within the Park represents a serious threat to marine and terrestrial ecosystems
in the Park. Clearing of St. John's steep hillsides on slopes approaching and exceeding 30 degrees has
resulted in elimination of native species, spread of exotic plants and non-native wildlife, 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 of exotic species, degradation of Park resources and scenic
values.

Intact forests are important habitat for migratory birds. Development of private lands within the Park and
construction of roads through watersheds which are now largely undisturbed could have adverse
consequences for the birds which winter in the Virgin Islands.


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Visitation Issues
Visitation to the Park by individuals is usually of a short-term nature. The annual number of visitors has
increased from around 120,000 in the early 1970's to over one million. Heaviest visitor use occurs
between November and May, and Wednesday through Friday, reflecting cruise ship arrivals. Most
visitors spend their time on, in or near the water. Beach use and boating are the most popular activities.
The beaches along the northwest shore between Cruz Bay and Cinnamon Bay receive the highest
concentration of use. Many tours are also taken to the premier cultural site at Annaberg Sugar Plantation.

It is desirable to provide a variety of opportunities for visitors, from concession operated/heavy use to
primitive surroundings/light use. Tourist influx to the Park continues to increase. Human carrying
capacities were established in the 1983 GMP for Park facilities, anchorages, recreational beaches and
Biosphere Reserve core areas and human impacts to resources were reduced in creative ways. These
carrying capacities need to be reevaluated in light of the trends in visitation since 1983. Congestion and
potential crowding threaten to impact not only the quality of the visitor experience but also the integrity
of scenic, natural and cultural resources. The Final Commercial Services Plan/EA (2001) identifies
desired future conditions that represents commercial use capacities which best balances resource
protection with a quality visitor experience. Trails, roads and facilities must be maintained and upgraded,
but not at the expense of the environment.

Starting in 1998, the Fee Demo Program instituted a fee collection program for Trunk Bay and Annaberg
Plantation. Visitors now pay $4.00 per person to visit both sites, whether by land or water. Of fees
collected, the Park retains 80% and can submit proposals to compete for the remaining 20%. In the first
years of this program, substantial funds have been collected for use in upgrading visitor facilities and
providing enhanced services, such as animal-proofing many trash receptacles and dumpsters.

Threats to Endangered and Threatened Species
Protection of threatened and endangered species and their habitat is imperative, as is reduction or control
of exotic and non-native species. Threatened and endangered species of plants are threatened by
development of inholdings and damage caused by non-native animals. Rooting activities of wild hogs is
damaging the Calyptranthes population on Bordeaux. Domestic goats and donkeys graze on seedlings
and saplings of rare plants and disperse the seeds of non-native species that compete with the rare species
for light and water.

Patrol rangers strictly enforce the pet leash and restriction laws, especially during turtle nesting season.
Dogs must be kept on a leash or physically restrained while in the Park (36 CFR 2.15). Dogs must be
kept off beaches in the Park where turtle nesting occurs. Dogs dig in the sand, sometimes finding the
scent of a sea turtle nest and dig it up.

The major threat to the reproductive success of threatened and endangered sea turtles is predation of eggs
and hatchlings by mongooses and rats. Predation of sea turtle eggs by mongooses is a learned response.
Mongooses see a dog or other mongoose digging a nest or find a recently dug nest and discover a high
protein source of food. Although sea turtles attempt to disguise the scent by dispersing sand with their
flippers, mongooses often detect it and dig to find the eggs. Mongoose predation accounted for up to a
23% loss of sea turtle eggs (Nellis & Small, 1983). Some beaches on St. Thomas experience 100%
predation of eggs and nests. Since they are the major predators and threat to nesting success, trapping
mongooses each season is necessary adjacent to nesting beaches.

Human poaching of threatened and endangered sea turtles and taking of eggs may be a problem in remote
areas of the Park. Sea turtle products, mostly hawksbill shells, are the most commonly confiscated
products by the U.S. Customs at United States borders. These confiscations are on the increase. Taking

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of adult turtles, mostly green, is still allowed in adjacent British waters. Public education, involvement of
volunteers with beach patrol programs and encouraging protection of the endangered and threatened sea
turtles in British waters, can raise community awareness about these ancient animals while reducing the
incidence of taking and poaching.

Turtle mortality due to boat strikes has greatly increased over the last fifteen years (Boulon, 1997). In
some years, over half of all reported turtle strandings involved damage to the carapace from boat
propellers or hulls. Increasing populations of juvenile green turtles and increasing numbers of high speed
powerboats results in increased numbers of incidental mortalities. The numbers of high speed boats
travelling along the north shore of St. John en route to the BVI continues to increase.

While other parts of the world (Southeast U.S., Hawaii) have been reporting large numbers of green
turtles affected with fibropapillomas, the USVI has only had a few reports of individuals having this
disease. However, reports of infected turtles are on the increase and sizes of reported tumors are also
increasing. This may become a great concern if this disease starts to affect a large segment of our turtle
population. Monitoring of in-water sightings and strandings must be maintained.

Endangered and threatened seabirds (Brown Pelican, Roseate and Least Ter) are most commonly
affected by predation on eggs and young by rats and mongoose. Humans are also potential poachers of
eggs in remote areas. Disturbance by human visitation to offshore cays results i low egg production,
death of chicks to sun exposure or even abandonment of the whole nesting colony. Decreases in baitfish
populations may limit nesting populations and affect the breeding and fledging success of these birds.

Non-native/Exotic Animal Impacts
Donkeys, domestic goats and wild hogs graze and browse on vegetation both inside and out of the Park.
Impacts to vegetation have been identified and recorded (Coblentz, 1983; Ray, 1990). Plants on St. John
did not evolve with grazers and browsers so have not developed defenses and survival tactics. Forest
structure and species composition is changing due to introduction of exotic plants in fecal matter and
disappearance of favorite non-native animal foods. Domestic goats are predominantly concentrated along
the east and southeast boundary of the Park. They are beginning to utilize Ram's Head, Annaberg, Reef,
Fish and Brown bays quite heavily. Hogs are centered around the Susannaberg landfill and have spread
from there to Bordeaux Mountain, Cinnamon Bay and Annaberg. Signs of rutting are now found in
Catherineberg, Reef Bay, Cinnamon Bay and Lameshur Bay. Donkeys wander the entire island. Young
black mangrove saplings (a protected species) are one of their favorite foods.

Recent introductions include two species of frogs from Puerto Rico and a bird. The Cuban Tree Frog is
thought to prey on species of smaller frogs such as our indigenous tree frogs. The "coqui" has been heard
around Caneel Bay. The house sparrow flew across the narrow mile wide channel separating St.
Thomas and St. John and has been seen around Cruz Bay. Audubon Society members are monitoring this
species and have attempted some reduction.

Non-native Norway and Tree Rat Impacts
Norway Rats (Rattus norvegicus) existed on St. John from the 1700's and were introduced by European
explorers. Black or Tree Rats (Rattus rattus) existed on St. John from the earliest records and were
possibly introduced by Taino Indians visiting from South America. Both species occur in Virgin Islands
National Park and range throughout St. John, but the tree rat is considerably more common. Most
problems arise from the nocturnal black rats, which reside in trees and generally forage only at night.
Tree rats are associated largely with people and human establishments.



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As commensal rodents, Norway and tree rats are habituated to living near humans and except for an
occasional predation by red-tailed hawks, they have no biological predators. Rats are omnivorous; they
eat nearly every kind of grain, fruit, fish, fowl, carrion, milk products, and vegetables. Several rodents
can destroy hundreds of chicks in just one night.

Rats gnaw to keep their incisor teeth sharp and worn down, as these teeth grow over 5 inches a year. This
gnawing causes considerable property damage. These rodents sometimes start fires when they damage
the insulation of electrical wiring. They may also use flammable materials like oily rags and matches for
building nests, which may cause fires from spontaneous combustion. Extensive damage is sometimes
done when rats burrow under buildings. Foundations and lower floors of buildings have been weakened
and some have collapsed when rats burrowed under them.

Large rat populations can only exist if sufficient food is available. Therefore, when the food supply is
reduced, the population will fall. Increased sanitation, more frequent trash pick-up, rodent-proofed trash
receptacles, and enhanced food preparation and storage practices can easily reduce the available food.
These changes should be well established before a large-scale population effort is initiated (Erickson
1987, Erickson and Halvorson 1990).

During dry periods, rats become more aggressive when their need for water increases. Also, when more
food becomes available their numbers increase dramatically in a short time. Basic education, routine
reductions, enhanced sanitation and basic monitoring will largely mitigate the rat problems. A successful
program will stress the long-term and ongoing nature of the solution. Too often, similar problems are
quickly arrested in the short-term, only to reoccur later when the original actions are slowed or
discontinued.

The West Indian Mongoose (Herpestes auropunctatus) came to the Caribbean and to St. John on a ship
from Calcutta about 1884. It was thought to be the salvation for the large sugar cane plantations on the
islands that were being ravaged by tree rats. At first, the statistics indicated that a very large rat population
decline had occurred and it was attributed to mongoose predation. As a result, in the next 30 years (1872
to 1900) even more mongooses were distributed throughout the Caribbean as a biological control.

Eventually, it was discovered that rats seeking their evening meals did not cross paths with the daytime
foraging mongoose. However, because rats are nocturnal and mongooses diumal creatures, they coexist
well. Problems compounded as the rats continued to enjoy sugar cane, while mongooses fed on bird and
sea turtle eggs, lizards, insects, papaya and guava.

Norway and tree rats enjoy the spoils of human habitation, and our garbage. The greatest rat
concentrations are believed to be near large human populations, Park campgrounds and day use areas.
There has been much effort and expense by the National Park Service to provide animal-proof trash
containers in the Park. Statistics show that if human garbage is controlled, the non-native rat population
will decline-a story similar to decline of bear-human conflicts in many other national parks in he
conterminous U. S. The actions with the greatest impact on reducing the number of rats involve reducing
or eliminating the available food on a regular basis.

Because reptiles, amphibians and invertebrates, such as insects, are small, often slow and readily available
on St. John, they are particularly susceptible to local extinction from non-native rat depredation. Of
particular concern are the varied native reptile and amphibian populations in the Virgin Islands National
Park and their links to the ecological web of the island. Rats prey upon three species of tree frogs, two
geckos, three Anolis lizards, the ground lizard, legless lizard, blind snake, the Puerto Rican racer, and the


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slipperyback skink. The Park has listed over 232 common insect species, including 13 species of
dragonflies and damselflies and over 1,500 beetle species; rats may eat all of which.

Great numbers of wildlife are lost each year to a relatively large non-native rat population. The
cumulative impacts associated with these increasing wildlife loses are very large. 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.

Non-native rats prey upon endangered hawksbill and leatherback sea turtles, which nest on St. John. Both
Norway and roof rats kill emergent hatchlings as they crawl from the nest to the ocean at night, when the
rats are most active. Rats will also prey upon sea turtle nests soon after being laid when the odor is still
present, eating many eggs and spoiling the remaining ones. The sea turtle recovery plans stipulate that
predators should be removed from turtle nesting beaches to protect species listed under the authority of
the Endangered Species Act.

Non-native rats prey upon chicks, juveniles and adults of most bird species that nest on St. John. Of
particular concern are endangered brown pelicans, least teams and threatened roseate teams. Territorial
endangered species preyed upon by rats include ground and tree nesting species such as bridled quail
dove, Bahama pintail duck, and the Antillean mango hummingbird, all of which suffer egg and chick
death due to rats. Rats also prey upon four (of the five) native bat species, three of which are territorially
endangered, and the only indigenous mammals on the island.

Non-native rats have established breeding populations throughout Virgin Islands National Park. Their
numbers are highest at Cinnamon and Trunk Bays, but smaller rats populations are present at Hawksnest
and Francis Bays, Annaberg Sugar Plantation, Saltpond Bay and Great Lameshur Bay. Rats are found
everywhere on St. John.

Food for non-native rats is present throughout the Park from a variety of sources, including trash
receptacles, roadside litter, and local wildlife. The natural environment of a small Park with numerous rat
populations, estimated at many thousands, will have a serious large and cumulative deleterious impact
from rats.

An intensive, rapid population reduction effort is necessary to reduce the present populations. A smaller
population will impact the natural environment less. Rats will enter the Park from adjacent lands, and
those inside will breed, thus rats must be periodically removed from the Park. The population must be
periodically censused to ensure the program goals to remove approximately 80% of the current population
of roof and Norway rats are achieved (Main, Hiemstra, and Long 1972; Amold 1986). Because
eradication is unfeasible, a rat population will remain of about 20% of the current population. A general
density threshold will be enacted whereby no rats should be seen in the daytime at any developed sites
within the Park.

A Non-native Rat Action Plan is necessary with the following elements: problem identification; general
density thresholds; enhanced food handling, storage and waste practices (including trash pickup
schedules); enhanced landscaping practices; written guidelines for visitors, NPS and concessions
employees; and routine removal and monitoring efforts. During periods with low moisture, rats become
more aggressive because their need for water increases. Also, when more food becomes available, their
numbers increase dramatically in a short time. Basic education, routine population reductions, enhanced
sanitation and basic monitoring will largely mitigate the rat problems throughout the development areas
(where they are found in highest densities). A successful program will stress the long-term and ongoing

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nature of the solution. Too often similar problems are quickly arrested in the short-term, only to reoccur
later when the original actions are slowed or discontinued.

Non-native Domestic Cat Impacts
Domestic cats originated from an ancestral wild species, the European and African Wild Cat (Felis
silvestris). The Domestic Cat (Felis catus) is now considered a separate species. The estimated numbers
of pet cats in urban and rural regions of the United States have grown from 30 million in 1970 to nearly
65 million in 2000. Reliable estimates of the present total cat population are not available. Nationwide,
approximately 30% of households have cats. In rural areas, approximately 60% of households have cats.
Populations of birds on oceanic islands have evolved in circumstances in which predation from
mammalian predators was negligible and they, and any other island vertebrates and invertebrates, are
therefore particularly vulnerable to predation when non-native cats have been introduced.

A growing body of literature strongly suggests that domestic cats are a very large factor in the mortality
of small mammals, birds, reptiles and amphibians. Because free-ranging cats often receive food from
humans, they can reach population levels that may create areas of abnormally high predation rates on
wildlife. When the wildlife prey is a threatened or endangered species, the results may be extirpation or
extinction. Effects of cat predation are most pronounced in island settings (both actual and islands of
habitat), where prey populations are already low or stressed by other factors, or in natural areas where cat
colonies are established.

Extensive popular debate over absolute numbers or types of prey taken is not productive. The number of
cats is undeniably large. Even if conservative estimates of prey taken are considered, the number of prey
animals killed is immense. Feeding cats does not deter them from killing wildlife, they do not always eat
what they kill. Humans introduced cats to North America and humans must be responsible for the control
and removal of cats that prey on wildlife.

The National Park Service fully supports the policy of The Wildlife Society (March 2001) which is to: 1)
strongly support and encourage the humane elimination of non-native cat colonies; 2) support the passage
and enforcement of local and state ordinances prohibiting the public feeding of cats, especially on public
lands, and releasing of unwanted pet or non-native cats into the wild; 3) strongly support educational
programs and materials that call for all pet cats to be kept indoors, in outdoor enclosures, or on a leash; 4)
support programs to educate and encourage pet owners to neuter or spray their cats, and encourage all pet
adoption programs to require potential owners to spray or neuter their pet; 5) support the development and
dissemination of sound, helpful information on what individual cat owners can do to minimize predation
by free-ranging cats; 6) pledge to work with the conservation and animal welfare communities to educate
the public about the negative impacts of free-ranging and non-native cats on native wildlife, including
birds, small mammals, reptiles, amphibians and endangered species; 7) support educational efforts to
encourage the agriculture community to keep farm cat numbers at low, manageable levels and use
alternative, environmentally safe rodent control methods; 8) encourage researchers to develop better
information on the impacts of non-native and free-ranging cats on native wildlife populations; 9)
recognize that cats as pets have a long association with humans, and their responsible cat owners are to be
encouraged to continue caring for the animals under their control; and 10) oppose the passage of any local
or state ordinances that legalize the maintenance of "managed" (trap/neuter/release) free-ranging cat
colonies.

Domestic cats have established breeding populations in many areas of the Virgin Islands National Park.
These colonies are termed non-native; the animals are neither domestic nor wild. Non-native cat
populations are highest at Cinnamon and Trunk Bays, but smaller colonies are present at Hawksnest and


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Francis Bays, Annaberg Sugar Plantation, Saltpond Bay and Great Lameshur Bay. Also, many cats live
independently of these colonies and range into and affect surrounding areas.

Cats hunt for both fun and food. Unlike wild predators, domestic cats hunt whether they are hungry or
not. These cats are called "subsidized predators" because they sometimes receive a steady supply of food
at home. Pet cats can hunt longer and are less susceptible to disease than many wild predators.

Because non-native cats routinely kill insects and other small animals for "sport" to practice their hunting
skills, in addition to using them as a food source, great numbers of wildlife are lost each year to a small
non-native cat population. A recent university study in Wisconsin ((Fish and Wildlife Today 1998)
estimated that 1 to 2 million free ranging rural cats in Wisconsin kill roughly as many as 217 million
birds each year." Researchers noted that birds make up only 20 percent of the cats' diet. Seventy percent
of the diet was small mammals and 10 percent reptiles and amphibians (Patronek 1997; Coleman and
Temple 1995). Thus, great numbers of wildlife can be lost each year to a small non-native cat population.

Virginia researchers compared free-roaming domestic pet cats in a rural setting and a more urban one. A
total of 27 native species (eight bird, two amphibian, nine reptile, and eight mammals, including the star-
nosed mole, a species of special state concern) were captured by a single rural cat. Four urban cats
captured 21 native species (six birds, seven reptiles, and eight mammals). Between January and
November 1990 each cat caught, on average, 26 native individuals in the urban area, and 83 in the rural
area. The study did not count prey killed and completely consumed, prey killed and left elsewhere, or
non-native prey (Mitchell and Beck 1992).

It has been extensively documented that domestic cats can severely impact seabird populations on islands
(Moores and Atkinson 1984), and well-fed cats still kill wildlife (Adamec 1976). Cats and other
predators can also have an impact on songbird populations in fragmented and isolated habitat (Wilcove
1985). In a scientific study in two Califomia parks-one with over 20 cats that were fed daily, and one
without cats, the researchers found that cats at artificially high densities, sustained by supplemental
feeding, reduced the abundance of native rodent and bird populations, changed the rodent species
composition, and may have facilitated the expansion of the house mouse into new areas. The scientists
recommended that the feeding of cats in parks should be strictly prohibited (Hawkins, Grant and
Longnecker 1999).

Because reptiles, amphibians and invertebrates are small, often slow and readily available, they are
particularly susceptible to local extinction from non-native cat depredation. Of particular concern are the
native reptile and amphibian populations in the Virgin Islands National Park and their links to the
ecological web of the island. Cats prey upon three species of tree frogs, two geckos, three Anolis lizards,
the ground lizard, legless lizard, blind snake, the Puerto Rican racer, and the slipperyback skink living on
St. John. The Park has listed over 232 common insect species, including 13 species of dragonflies and
damselflies and over 1,500 beetle species; cats may eat all of which.

The cumulative impacts associated with these increasing wildlife loses can be very large. 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 on a larger landmass.

Domestic or non-native cats kill chicks, juveniles and adults of most bird species nesting on St. John. Of
particular concern are endangered brown pelicans, least tears and the threatened roseate tears. Cats may
also prey upon hatchling hawksbill sea turtles as they travel from nest to the sea at night. The sea turtle


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recovery plans stipulate that predators should be removed from turtle nesting beaches to protect species
listed under the authority of the Endangered Species Act.

Non-native cats also prey upon four (of the five) native lat species, three of which are territorially
endangered, and the only native mammals on the island. Other territorial endangered species include
ground and tree nesting species such as bridled quail dove, Bahama pintail duck and Antillean mango
hummingbird, all of which may suffer egg and chick death due to cats. The Endangered Species Act
stipulates that predators should be removed from nesting sites to protect species listed under the
Endangered Species Act.

Wildlife officials believe the best way to reduce the damages to bird, reptile, amphibian, insect and other
small wildlife populations from free-ranging cats is for cat owners to keep their pets indoors. Many
stateside municipalities currently have ordinances that require cats to be kept indoors or on a leash.
However, these measures are rarely enforced.

Foods are present throughout the Park from a variety of sources, including trash receptacles, roadside
litter, and local wildlife. In addition, feeding by visitors and residents occurs regularly. Non-native
animal behavior ranges from being completely tame and affectionate too wild and aggressive.

As a result, many cats will continue to suffer due to rejection from established territorial colonies and the
resultant insufficient food supply. IVbre cats will fight and more will have insufficient nourishment as
their populations increase. At the same time, they will breed and produce more animals to exacerbate the
problem. A small Park with numerous non-native cat populations estimated at numbering from 15 to 30
animals is negatively impacting the natural environment.

The cat problem is exacerbated because people routinely abandon kittens and adults within and near Park
boundaries. The owners believe the cats will be taken care of in the Park and would be dispatched if
taken to the Humane Society. They are partially correct, because people routinely feed cat colonies in the
Park, and many animals must be destroyed by the Humane Society.

Any viable solution must include a partnership with the local community and ongoing outreach and
education efforts. This partnership should include the local non-profit St. John Animal Care Center
because some members have routinely fed non-native cat populations within and near Park boundaries
(American Veterinary Medicine Association, Animal Welfare Forum 1996).

Non-native West Indian Mongoose Impacts
In the 1880's, European planters introduced the West Indian Mongoose (Herpestes auropunctatus) to the
Caribbean and to St. John as a biological control to suppress the tree rat populations that decimated sugar
cane fields (Nellis and Everard 1983). It was thought to be the salvation for the large sugar cane
plantations on the islands that were being ravaged by tree rats. At first, the results indicated that a very
large decline in the rat population had occurred and the decline was attributed to mongoose predation. As
a result, in the next 30 years (1872 to 1900), even more mongooses were distributed throughout the
Caribbean as a biological control.

Soon it was discovered that rats that sought out their meals at night didn't cross paths with the daytime
foraging mongooses. Rats are nocturnal and sleep in trees during the day. They were therefore able to
eat as much sugar as they wanted by night, while the mongooses were sleeping. The rats were safe,
during the day, from the mongooses, which cannot climb trees. They coexist well and we now have both
exotic species to contend with. Mongoose populations are scattered throughout St. John, with the highest
concentrations near human populations, due to increased food availability. Mongooses have no biological

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predators and populations rise sharply when sufficient food quantities become available (Nellis and Small
1983).

Problems compounded as the rats continued to enjoy sugar cane and the mongoose feasted instead on bird
and sea turtle eggs, as well as insects and fruit. Public health concerns increased when the mongoose was
discovered to be a carrier of rabies. Since mongooses have no natural predators here, the checks and
balances of natural population control are missing.

Non-native mongooses enjoy the spoils of human habitation and garbage. The greatest mongoose
concentrations are near human populations, Park campgrounds and day use sites. There has been much
effort and expense by the National Park Service to provide animal-proof trash containers in the Park.
Statistics show that if human garbage is controlled, the mongoose population will decline-a story similar
to decline of bear-human conflicts in many other national parks in the conterminous U. S. The actions
with the greatest impact on reducing the number of mongooses involve reducing or eliminating the
available food on a regular basis.

No one knows the exact mongoose population on St. John, though the speculation is that there are an
estimated population of 330 to 400 animals concentrate along the moister northern shore. They do not
construct a nest, but curl up on the leaf litter to sleep at night. The average size of a mongoose family is
mother and two offspring that are carried for 49 days. Their eyes open at 16 days and their first venture
from their nests is at 25 days. They have a full set of teeth at 22 weeks. An interesting bit of trivia is that
the weight of the lens of the eye is an indicator of the age of a mongoose. The average mongoose will
claim about 8 acres as their territory (Nellis and Everard 1983).

Because reptiles, amphibians and invertebrates are small, often slow and readily available, they are
particularly susceptible to local extinction from being preyed upon by non-native mongoose. Of particular
concern, are the varied native reptile and amphibian populations in the Virgin Islands National Park and
their links to the ecological web of the island. Mongooses prey upon three species of tree frogs, two
geckos, three Anolis lizards, the ground lizard, legless lizard, blind snake, the Puerto Rican racer, and the
slipperyback skink. The Park has listed over 232 common insect species, including 13 species of
dragonflies and damselflies and over 1,500 beetle species; mongooses may eat all of which.

Mongooses enter a "feeding frenzy" behavior, during which they kill and maim every insect and other
small animals they encounter, in addition to using them as a food source. Great numbers of wildlife,
therefore, are lost each year to a relatively small mongoose population. The cumulative impacts
associated with these increasing wildlife loses are very large. 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 on a larger landmass.

Non-native mongooses are primary predators of endangered hawksbill and leatherback sea turtles, which
nest on the island. Mongooses will prey upon sea turtle nests soon after being laid when the odor is still
present, eating many eggs and spoiling the remaining ones (Nellis 1982; Nellis and Small 1983; Coblentz
and Coblentz 1985). They will also prey upon a nest just before or immediately after hatching as the
emergent hatchlings crawl from the nest to the ocean in the early morning hours, when mongooses begin
to hunt. Often, hatchlings trickle from their nesting cavity over a period of several hours, leaving them
susceptible to mongoose predation in the daytime. The sea turtle recovery plans stipulate that predators
should be removed from turtle nesting beaches to protect species listed under the authority of the
Endangered Species Act.


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Non-native mongooses prey upon chicks, juveniles and adults of most bird species that nest on St. John.
Of particular concern are their preying upon endangered brown pelican, least ter and the threatened
roseate ter. Territorial endangered species preyed upon by mongooses include: ground and tree nesting
species, such as bridled quail dove and Bahama pintail duck; and the Antillean mango hummingbird, all
of which suffer egg and chick death due to mongooses.

Non-native mongooses also prey upon four (of the five) native bat species, three of which are territorially
endangered, and the only indigenous mammals on the island. The Endangered Species Act stipulates that
predators should be removed from nesting sites to protect species listed under the authority of the
Endangered Species Act.

Mongooses have established breeding populations throughout Virgin Islands National Park. Their
numbers are highest at Cinnamon and Trunk Bays, but smaller mongoose populations are present at
Hawksnest and Francis Bays, Annaberg Sugar Plantation, Saltpond Bay and Great Lameshur Bay.
Mongooses are ubiquitous on St. John.

Mongoose foods are present throughout the Park from a variety of sources, including trash receptacles,
roadside litter, and local wildlife. In addition, feeding by visitors and residents occurs occasionally. A
small Park with numerous non-native mongoose populations with an estimated number of 300 to 400
animals will have a very serious deleterious effect on the natural environment.

The actions to reduce non-native rats have the double advantage of also limiting mongoose populations
(Nellis and Small 1983, Boulon 1999). The actions with the greatest impact on reducing Ihe number of
mongooses involve reducing or eliminating the available food on a regular basis (Nellis 1982).

Biological Pollution (Exotic Plants)
Harmful exotic plants can have profound environmental consequences ranging from wholesale ecosystem
changes aid extinction of indigenous or native species, especially on islands, to more subtle ecological
changes and increased biological sameness (monospecific forests). Both intentional and accidental
introductions of harmful non-indigenous plants occur. Intentional introductions take the form of
ornamental plants to enhance perceived beauty or of crops, fruit trees and medicinal plants to generate a
new source of food or income. Accidental introductions arrive as contaminants or hitchhikers on bulk
commodities, packing material, in ship ballast, seed shipments and soil. Agricultural inspections of plants
entering the Virgin Islands through customs are cursory at best. No inspections are done on cargo
transported between the Virgin Islands. An inventory of exotic species and determination of their status
in the Park are needed. If the species interferes with Park objectives, has the ability to alter ecosystems,
can spread to natural communities, can out-compete native species or is allellopathic, management
actions need to be evaluated and implemented.

Forest Recovery, Fragmentation and Vegetation Removal
Altered and degraded forest systems are recovering from the clear-cutting done in plantation days. Most
species are still present, but composition and forest structure do not yet resemble pre-plantation
descriptions of the forests. Ecological succession to dominant communities is being monitored. Grazing
and browsing by non-native livestock and development pressures are the worst threats. The few
remaining mangrove forests have been considerably stressed by recent hurricanes: Hugo (1989), Luis
(1995), Marilyn (1995), Bertha (1996) and Georges (1998) and development pressures. Fragmentation of
small natural areas into even smaller parcels is a threat to natural systems and processes.

Vegetation removal is done frequently. The Park maintains seven scenic vistas and 34 kilometers (21
miles) of Park trails, and mows the roadside along the North Shore Road. Volunteer groups from the

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community, the American Hiking Society, the Appalachian Mountain Train Club and other interested
parties have assisted with keeping trails open for hikers. A vegetation removal guide and training are
needed to protect native saplings, endangered and threatened species, and ensure the safety of workers
from poisonous plants with toxic sap and thorns.

Taxi drivers have illegally removed vegetation to make additional scenic vistas. People in the community
also cut and collect plants for crafts, livestock and gardens. Endangered, threatened and rare species need
protection from these illegal and largely covert activities. Increased education, institution of broader
collection permits requirements and increased ranger patrols are necessary to reduce illegal vegetation
removal.

Garbage Disposal and Recycling
Until 1994 the St. John solid waste disposal site was an open landfill located at Susannaberg, 2.4
kilometers (1.5 miles) east of Cruz Bay, south of Centerline Road. The Territorial Department of Public
Works manages it. This landfill served the needs of the entire island, including the Park until it was
closed after a large fire erupted and eventually was put out in 1992. The landfill has been capped and
closed according to the Environmental Protection Agency's standards, however, leachates carrying
contaminants may wash down Guinea Ghut or seep into the groundwater during heavy rainstorms.
Garbage generated on St. John is still taken to the landfill site, where it is loaded onto trucks, barged to St.
Thomas and deposited in the Bovoni landfill. That landfill has also exceeded capacity and resource
recovery alternatives are being explored by the VI Government for that landfill.

Twelve percent of the contents of the landfill are metal, 40% is paper and 5% is glass. If just these
materials were recycled, the volume of garbage going to the landfill would be decreased by over 50%. If
composting household garbage, grass and leaves were done; another 23% in volume would be reduced.
The Park, the VI Anti Litter and Beautification Commission (VIALBC) and a few key local citizens has
initiated recycling programs for aluminum. Recycling would decrease the volume of garbage sent to the
landfill as well as save energy. Ninety percent of the energy it takes to manufacture aluminum from
virgin materials can be saved if aluminum is recycled.


III.C. CULTURAL RESOURCES

This section of the Environmental Assessment describes the current status of baseline information from
inventories, monitoring and research projects. Major Park planning documents have been completed.
Some are in the process of being updated; the Land Use Plan, Statement for Management, and the
Resource Management Plan. Virgin Islands National Park needs an update to major inventories and
documentation of cultural resources in addition to special studies and an administrative history.

History
Three waves of migrations brought Native Americans north from the Orinoco River valley of Venezuela.
By the time of European discovery of the New World, two prehistoric Indian groups inhabited or visited
the Virgin Islands, the Arawaks or Tainos and the more aggressive Caribs. On November 4, 1493,
Christopher Columbus and a fleet of 17 ships made land fall in the Lesser Antilles beginning two
centuries of international wars for supremacy of the West Indies, disrupting native customs and
deforesting the land. The Columbus expedition did land on St. Croix, probably at Salt River.

Beginning in 1718, St. Thomas and St. John were colonized by the Danish West India and Guinea
Company. Landholdings were cleared and cultivated. These "plantages" or "plantations" relied on slave
labor and sizable capital investment. On St. John in 1733-4, development was slowed and nearly stopped
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by an almost successful slave uprising. The Danish West Indies became a crown colony in 1755 and
development accelerated. By 1780, the greater part of St. John was under cultivation. Early crops
included cotton, tobacco and dye woods such as indigo, but shifted predominantly to sugar. The rugged
terrain, the thin rocky soil and labor-intensive economies created problems. As long as sugar prices
remained high and African slaves were easily available, agricultural development was financially viable.
Denmark abolished trade in slaves in 1792. By the 1800s, sugar prices dropped. Plantation economy
became marginal. By the mid-1800s, competition with areas where mechanical cultivation of both sugar
and cotton and the increased production of the European sugar beet was too much and some plantations
folded. In 1848 slavery was abolished in the Danish West Indies. The plantation systems succumbed.
Only a few plantations lasted into the 20th century. They introduced crops that produced bay and lime
oil, mechanically crushed sugar, or they attempted to raise and sell livestock.

The breaking point for most remaining plantations occurred in 1867. Following a major hurricane and
earthquake, tracts of cultivated land were abandoned or allowed to shrink. The population declined.
Land reverted to natural vegetation that buried the collapsing remains of the once flourishing agricultural
buildings. In 1917, the Danish West Indies was ceded to the United States. The territory of the Virgin
Islands was created in 1931 and is currently administered by an elected governor and legislature.
Oversight authority for the territory rests in the U.S. Department of Interior.

Now the islands are based on a tourist economy. After World War II, with rising wages and improved
large-scale commercial air travel, mass tourism became reality. The over one million tourists per year
originate predominantly from the United States (64%), Europe (10%) and Canada (7%). Beginning in the
1950s, St. Thomas became a popular destination for Caribbean cruise ships that send passengers to St.
John for day trips. The island, which once harbored fewer than 800 people living mostly in two-room
wooden cottages without indoor plumbing, electricity or telephones and their only means of transportation
a donkey or a horse, has undergone a dramatic transformation. A population of over 4,500 persons is now
sustained by wage employment that allows many to live in modem housing and own cars.

The Virgin Islands National Park was welcomed when it was established in 1956 on St. John. It was
thought that the Park would provide economic opportunities for local Virgin Islanders. But, the Park has
been developed as a "natural area", following a U.S. concept of nature foreign to St. Johnians. The
general policy adopted by the Park dictated that land be "managed 'back' toward pristine condition" that
had prevailed "when the area was first visited by the white man" (Administrative Policies 2001). Access
to economic resources in the Park has been restricted, severely limiting traditional use of the environment.
The tourist industry created only limited economic opportunities for St. Johnians.

After the Park was established, it undertook the task of undoing the effect of almost 250 years of
cultivation. If a St. Johnian had a garden plot under cultivation on land acquired by the Park, the plot
could continue to be cultivated but no new land could be cleared. Soil was depleted within several years
and the traditional extensive swidden agriculture ceased. Cattle grazing on Parklands were forbidden. No
longer permitted to turn their cattle loose on a nearby estate during periods of drought, farmers were
forced to slaughter them. Even though hunting and trapping had never been a major part of the local
economy, the Park set up large signs prohibiting it. There was a fine of $500 or six months in prison for
any person violating Park rules.

Archeological Sites
The Virgin Islands prehistorically are part of a larger Caribbean Culture Area. This area consists of two
distinct chains of islands. The Lesser Antilles are a line of small, mainly volcanic islands sweeping
northward from Trinidad near the mouth of the Orinoco River in Venezuela. The Greater Antilles consists


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of a chain of four large islands: Puerto Rico, Hispaniola (Haiti and the Dominican Republic), Cuba and
Jamaica. American Indians prior to discovery inhabited the Virgin Islands by the Spanish explorers.

The earliest occupation of the Americas was detected around 10,000 BC. During the last glaciation when
a land bridge formed between Asia and North America, small highly mobile bands of hunters and
gatherers reached America. They hunted large megafauna such as the mastodon and mammoth. It is not
thought that the Antilles were inhabited during this period (13,000 to 7,900 BC). The earliest recorded
prehistoric site for the Caribbean Culture Area is the El Jobo Site in Venezuela. This culture was
probably an offshoot of the North American big game hunting tradition.

During the next period of time, the hunter/gatherer groups became more organized and spread out. They
developed storage pits, began collecting shellfish, developed habitations, prepared their dead for burials,
traded with other groups and developed the atlatyl to increase hunting prowess. This period of time is
called Archaic on the mainland (8,000 to 1,000 BC) and Meso-Indian in the Caribbean (5,000 BC to AD
0). The only known site representing this period of time in the Virgin Islands is the Krum Bay Site on St.
Thomas although there may be a site as old as 700 AD at the west end of Cinnamon Bay beach.

The third broad period of pre-history is called the Neo-Indian in the Caribbean (AD 0 to contact with
Europeans). During this period of time, there was an increase in horticulture, ceramic pottery use and
there was a shift to a more sedentary lifestyle. Several waves of culture groups left the Orinoco valley in
Venezuela and migrated northwards. Just a few hundred years prior to contact with Europeans, the
Arawaks had begun to be displaced by this last migrant group. By European contact, the Caribs had
occupied all of the Lesser Antilles including the U.S. Virgin Islands.

Twenty-two prehistoric sites have been recorded on St. John, thirteen of which are on National Park
Service land. Only two of these sites are currently on the National Register, the Reef Bay petroglyphs
and the Cinnamon Bay site. Nine additional sites may be eligible for National Register listing. The largest
and best-known site on St. John is at Coral Bay outside the Park boundary.

The subsistence economy of these Archaic people was based on collecting plants, fishing and small game
hunting with an emphasis on the exploitation of maritime resources. No large mammals were present on
St. John. The Iguana (Iguana iguana), Hutia (Isolobodan), and several bird species provided land-based
meats. The hutia, a small rodent-like animal, and the iguana are thought to have been introduced to St.
John by Arawak settlers. Reef fish were the most important and easiest to exploit. The Manatee
(Trichechus manatus) was known to have been used by aboriginal and historic settlers alike. Shellfish
were abundant, with Conch (Strombus sp.) and the West Indian Topshell (Cittarium pica) being found the
most often in the archeological record. Spiny lobster and crabs were also utilized for food. Recent
evidence from Cinnamon Bay shows that the Caribbean Monk Seal as well as freshwater turtles, snakes
and a number of rails were also consumed.

Non-native wild hogs and domestic goats damage irreplaceable archeological and historical sites and
degrade the scientific importance of the St. John Archeological Districts located at Cinnamon and Reef
bays. Damage to archeological and historical sites by hogs and goats continue essentially unabated. Hog
rooting of archeological sites on the island has resulted in their loss of integrity, and ultimately loss of the
values that make the St. John Archeological Districts eligible for the National Register of Historic Places.

Historic Structures
The most conspicuous structures, both in volume and size, are the remains of sugar plantations. They are
found predominantly along ridges of the north coast and valleys of the south coast of St. John, where


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drainages were good for growing sugar cane. On drier areas of the island, cotton and livestock were
raised.

Consolidation of small landholdings to larger economically feasible ones occurred over time. From 1728
Danish tax records, 91 plantation lots were counted on St. John. Only half of these were under
development. Seventy-two years later, in 1800, P.L. Oxholm mapped 68 plantations, 41 of which were
within the current authorized Park boundaries. Currently there are 46 historic plantations within the
authorized boundary, 31 of these are on federal land.

There are 236 historic structures on the 1989 List of Classified Structures for St. John. Seventeen of these
are still roofed or with vestiges of roofing. Nine structures are in use. Sixteen historic districts are
recorded on the National Register, all of which are on federal land. These contain 180 individual
structures. Seven individual structures are recorded on the National Register, four of which are on federal
land. Structures range in function from Danish plantation great house, cook house, slave village and
sugar processing factory to colonial fort and battery, to a school and even a guard custom house. They
date from 1718. Many of the structures have fallen to ruinous piles of rock not considered salvageable
and should be removed from the List of Classified Structures (LCS) and added to the Cultural Sites
Inventory (CSI) as historic archeological sites. Basic inventories are not complete. Portions of structures
and new historic archeological sites hidden by years of vegetative growth are still being discovered.
Historic structure reports have not been completed for most structures undergoing stabilization.

No National Landmarks are yet listed for the island of St. John, although there are six worthy of
nomination. Two sites were nominated in 1994: Fortsberg and the Reef Bay Great House Plantation
manager or owner residences were usually with the area of production or on higher ground overlooking
the factory. Slave quarters or "villages" were placed on the periphery of the production center. Most
plantations included an orchard and plot for raising vegetables. Terrain dictated the pattern, either grid or
terracing with walls. Existing roads and trails generally follow original cart roads that should also be
considered part of the cultural resource.

Architecture was rural in character and utilitarian of purpose. The most common construction was rubble
masonry using locally available fieldstone set in lime mortar with liberal use of imported brick for
framing doors, window openings, arches and quoining of comers. Much rubble and brick masonry has
traces of a parged or plaster finish. Stucco inlays of colored plaster ornamentation was frequent in
principal buildings. The Reef Bay Great House and Hammer Farm are excellent examples of the use of
ornamentation. Characteristic, but not common, was the use of blocks of cut and fitted brain coral that
was usually left exposed. Annaberg is an excellent example of this architectural style. Clay wing tile,
both glazed and unglazed, was not an unusual roofing material. Flooring made of brick, clay tile or
Gotland limestone flagging was widely used. The few remaining well-preserved structures indicate that
workmanship was excellent.

The most significant and complete historic structures on St. John under Park jurisdiction have been
cleared of vegetation and stabilized to provide a degree of protection against further deterioration. The
work has been predominantly limited to masonry repair of standing walls. The Reef Bay Sugar Factory
has been re-roofed with lightweight modem galvanized-type roofing to protect the machinery and other
features of the interior. Significant structures that have been stabilized include the Reef Bay Sugar
Factory which is the best preserved example of technology used in mid-19th century sugar making, the
Cinnamon Bay sugar plantation which was one of the first established on the island and site of significant
events during the 1733 slave rebellion, the Annaberg sugar plantation illustrating an excellent example of
a complete factory complex, and the Hammer Farm (also called Catherineburg) windmill tower with
unique ramp and vaulted storage.

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The Reef Bay Great House is considered the most important historic structure in the Park and illustrates
West Indian formal architecture. It is on the National Register (H-15) and has been nominated for
National Historic Landmark status. Fish plates and tie rods were installed in some walls of the Reef Bay
Great House to increase structural strength, but have now been removed. Reconstruction of the walls of
southwest comer was needed to stabilize it and keep it from imminent collapse. This was completed in
1993. The structure has also been re-roofed with sheets of galvanized aluminum. Plastering of the
exterior is still needed.

Fourteen known historic districts and one individual building exist on inholdings within the authorized
boundary on St. John. Nine of them may qualify for nomination to the National Register for their
historical associations and their integrity. They include: Caneel Bay Plantation (H6); Susannaberg
Plantation (H7); Adrian Plantation (H8); Oynes Point Custom Guard House (H9); Leinster Bay Plantation
(H29); More Hill (H38); Frederiksdal and Mount Pleasant (H41). The State Preservation Office has
nominated two of them to the National Register: Frederiksvaem, Fortsberg, Coral Bay (H44); and
Whistling Cay Customs Guard House (H47).

Rats gnaw to keep their incisor teeth sharp and worn down, as these teeth grow over 5 inches a year. This
gnawing causes considerable property damage. These rodents sometimes start fires when they damage
the insulation of electrical wiring. They may also use flammable materials like oily rags and matches for
building nests, which may cause fires from spontaneous combustion. Extensive damage is sometimes
done when rats burrow under buildings. Foundations and lower floors of buildings have been weakened
and some have collapsed when rats burrowed under them.

The major environmental impact to the historic structures is growth of vegetation and undermining of
historic structures by burrowing, vegetation grazing, and fecal and urine contamination by non-native rats.
Plants penetrate soft mortar and plaster surfaces working themselves deeper into the structure forming
cracks through pressure against surfaces as they grow and providing avenues for moisture and rainfall to
enter. Consistent, constant removal of vegetation continues to be one of the major efforts in stabilizing
major Park structures. By removing rats from these sites, there would be safer, cleaner, healthier and
more stable structures for interpretation and enjoyment.






















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IV. CHAPTER IV. ENVIRONMENTAL

CONSEQUENCES


Chapter IV discloses the environmental consequences of implementing each of the six alternatives
described in Chapter II. This analysis of environmental consequences is largely a qualitative assessment
of the effects of the alternatives on twelve natural and cultural resources categories.



IV.A. Non-native Rat Control

III.B.1. Alternative 1. No Action, Continue Current Level of Management

Air Quality Impacts
No adverse air quality impacts would be expected under this alternative.

Scenic Values
Scenic values would decline under this alternative as native flora and non-native rats increasingly
depredate fauna because rats would continue to eat many types of wildlife that the public hopes to see
during a visit to VINP. The aesthetics near dumpsters would decline as trash is scattered and carried into
the bush and nearby roadsides. The natural and cultural resource values of the island would decrease.

Cultural Resource Impacts
Non-native rats would continue to damage irreplaceable archeological and historical sites and would
degrade the scientific importance of the St. John Archeological District. Under this alternative, damage to
archeological and historic sites by rats would continue essentially unabated. Cultural resource impacts
would increase at historic sugar plantations throughout the Park and particularly near developed areas
with heavy visitation. The burrowing, vegetation grazing and seed dispersal would continually undermine
the historic fabrics, increasing destabilization and vegetation removal costs and frequencies. Extensive
damage is sometimes done when rats burrow under buildings. Foundations and lower floors of buildings
have been weakened and some have collapsed when rats burrowed under them. Rats alter forest
composition by selectively feeding on palatable species and distributing the seeds of exotic species
through their feces. Fecal and urine contamination throughout these valuable resources would continue
unabated, causing health and safety concerns for visitors at these sites.

Socioeconomic/Visitor Use Impacts
Tourism may slightly decrease, especially overnight stays at camping facilities, under this alternative.
The visitor experience would decline because if visitors visit fewer sites and stay shorter periods because
of negative experiences with non-native rats. This is especially true if people encounter rats during
daylight hours anywhere in the Park, but particularly in eating facilities and sleeping quarters. Virgin
Islands National Park campgrounds are severely impacted by rat populations entering tents, eating food
and other items and depositing fecal materials on personal belongings.

Soil Impacts
Soil impacts would remain unchanged under this alternative. This alternative would not implement any
large reductions in the non-native rat population. However, increased rat tunneling within, under and
adjacent to historic or modem structures would continue to decrease their stability. More tunnels within

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which seeds are transported could undermine the stability and integrity of all buildings and especially the
cultural landscapes.

Threatened and Endangered Species Impacts
Non-native rats were identified as a potential threat to each of the Federally or Territorially listed
Endangered and Threatened (T&E) plant and animal species found on St. John Island. Under this
alternative, the threats to each of the listed species would remain. Rats would continue to predate listed
species. Listed species include the Endangered Hawksbill and Leatherback sea turtles (eggs and
hatchlings), Endangered Brown Pelicans and Least Terns, and Threatened Roseate Terns (eggs and
chicks).

Rats also depredate four (of 1he five) native bat species, three of which are Territorially Endangered, and
the only indigenous mammals on the island. Other Territorial Endangered species include ground and
tree nesting species such as Bridled Quail Dove, Bahama Pintail Duck and Antillean Mango
Hummingbird, all of which suffer egg and chick depredation due to non-native rats.

Vegetation Impacts
Under this alternative, no eradication efforts would be used on non-native rats on St. John Island. Their
population numbers would continue I) rise and fall with the seasonal and long-term availability of food
resources. There would be no change in the type or level of impacts to native vegetation under this
alternative. This is particularly important in the dry season, when bark and leaves are consumed for their
moisture content. In addition, fewer seeds from exotic plant species would be dispersed in rat fecal
matter and in burrows. This complex ecological problem is exacerbated over time as the accumulative
affects multiply and have a greater influence on the vegetation island-wide, as well as the fauna and
micro-habitats found within the vegetation.

Wildlife Impacts
The non-native rat population, estimated at from 2,000 to 2,400 individual animals, would continue to
fluctuate due to annual differences in weather. Native wildlife would be adversely impacted by this
action because very large numbers of native fauna including several native bird, reptile and amphibian
species and numerous insect and spider species are depredated by Norway and roof rats.

Because herptofauna and invertebrates are small, often slow and readily available, they are particularly
susceptible to local extinction from non-native rat depredation. 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. Rats prey upon three species of tree frogs, two geckos, three Anolis lizards, the ground lizard,
legless lizard, blind snake, the Puerto Rican Racer, and the Slipperyback Skink. The Park has listed over
232 common insect species, including 13 species of dragonflies and damselflies and over 1500 beetle
species, many of which are preyed upon by rats. Many invertebrate species may be lost before
researchers have catalogued them.

Water Quality Impacts
No adverse water quality impacts would be expected under this alternative.

Wetlands/Floodplain Impacts
Adverse impacts to wetlands, mainly saltponds, would continue under this alternative as the native flora
and fauna continue to change under the foraging and predation pressure of rats throughout the Park. This
is especially problematic where salt ponds occur near centers of human activities, e.g. Annaberg Sugar
Plantation.


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Park Operations Impacts
Highest potential for adverse operational affects from non-native Norway and roof rats on the Park's
administrative, resources management, interpretation, law enforcement and maintenance costs would be
expected to continue. Under this alternative, NPS would continue to animal-proof trash receptacles and
dumpsters at campgrounds, day use sites, concession areas, park overlooks, and employee housing areas.
During the last year, Virgin Islands NP has purchased and installed over 50 pre-manufactured animal-
proof trash containers (at a cost of about $75,000) at all Park sites except at the major concession
operations at Trunk Bay and Cinnamon Bay to collect both refuse and recyclables. In fiscal year 2002,
the NPS requested $30,000 in funding to purchase and install an additional 20 pre-manufactured animal-
proof trash containers at major concession operations (eight at Trunk Bay and twelve at Cinnamon Bay)
to collect both refuse and recyclables. Also in 2002, NPS has contracted for the construction of a donkey-
exclusion fence with four barbed-wire strands around the perimeter of the Cinnamon Bay Campground at
an estimated cost of $67,000.

Cumulative Impacts
The cumulative impacts from this alternative would have severe negative consequences for National Park
Service lands and wildlife. Every native terrestrial plant, animal and invertebrate species would be
adversely impacted under this alternative. The greatest impact would be changes in plant species
composition and the associated changes in native fauna, including birds, bats, tree frogs and insect
species. Eventually, many species would become locally extinct, some before they are even identified by
researchers.

Under this alternative, no baiting would take place and therefore, risk of rodenticide exposure would be
restricted to non-target species in and around Park buildings where non-native rat control with
rodenticides would continue to take place.

Health and sanitation conditions would continue to decline under this action. More rats would disperse
more disease causing organisms in more places, including tents, picnic tables, sinks and bathing facilities.
Problems in campgrounds would continue and some people may choose not to visit St. John as a result,
and those who do may reduce their stay and have a negative experience. This is certainly true when rats
must forage for food in the daytime as populations exceed carrying capacities.

This alternative would adversely affect the approved Coastal Zone Management Plan that supports the
removal of non-native pests that damage the coastal zone and wildlife therein, and policies of the Territory
of the U. S. Virgin Islands for reasons described above.


III.B.2. Alternative 2. Proposed Action Sustained Reduction

Air Quality Impacts
No adverse air quality impacts would be expected under this alternative.

Scenic Values
Scenic values would be enhanced under this alternative as the native flora and fauna species depredated
by non-native rats' increase, resulting in more native fauna and flora sightings because rats would no
longer continue to eat many types of wildlife that the public hopes to see during a visit to VINP. The
aesthetic environment near dumpsters would be enhanced when trash and food wastes are not seen and
offensive odors are reduced. The natural and cultural resources values of the island would greatly
increase.


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Cultural Resource Impacts
Non-native rats would no longer continue to damage irreplaceable archeological and historical sites and
degrade the scientific importance of the St. John Archeological District. This alternative would result in
the most rapid reduction of rats and, therefore, the least continued damage to cultural resources through
rat depredations on archeological and historical sites. Cultural resource impacts at the numerous historic
sugar plantations throughout the Park and particularly near developed areas would be mitigated by greatly
decreasing the rat population and sustaining the reduction. This effort would reduce the impacts from
burrowing, vegetation grazing and fecal and urine contamination throughout these valuable resources.
Extensive damage is sometimes done when Norway rats burrow under buildings. Foundations and lower
floors of buildings would no longer continue to be weakened and some have collapsed when rats
burrowed under them. Rats would no longer continue to alter forest composition by selectively feeding on
palatable species and distributing the seeds of exotic species through their feces. The result would be
safer, cleaner, healthier and more stable structures for interpretation and enjoyment.

Socioeconomic/Visitor Use Impacts
Visitor use patterns should be enhanced with a possible tourism increase under this alternative or at least a
reduced decline attributable to non-native rats. Potential visitors who opted to vacation in another area as
the result of media coverage or word-of-mouth communication about the rat problems may visit when the
problems are resolved. The tourist experience at Virgin Islands National Park would be greatly improved.

Soil Impacts
Soil disturbing activities from non-native rats would be eliminated within several years of implementation
of this alternative. However, decreased tunneling within, under and adjacent to historic or modem
structures would increase their stability. Fewer tunnels within which seeds are transported would enhance
the stability and integrity of all buildings and especially the cultural landscapes. A reduction in
vegetation removal expenses may be realized as well.

Threatened and Endangered Species Impacts
Under Alternative Two, non-native rats would be quickly reduced as a threat to each of the Federally or
Territorially listed Endangered and Threatened (T&E) plant and animal species found on St. John Island.
Under this alternative, the threats to each of the listed species would be completely eliminated by the
sustained reduction program. Both Norway and roof rats depredate eggs or chicks from all birds nesting
on St. John. Of particular concern is depredation to Endangered Brown Pelicans (Pelecanus
occidentalis), Least Terns (Sterna antillarum), and the Threatened Roseate Terns (Sterna dougallii).
Territorial endangered species include ground and tree nesting species such as Bridled Quail Dove,
Bahama Pintail Duck and Antillean Mango Hummingbird, all of which suffer egg and chick depredation
due to rats. Rats are not primary predators of Endangered Hawksbill (Eretmochelys imbricata) and
Leatherback (Dermochelys coriacea) sea turtles that nest on the island; however, rats are involved in
predation events each year. Both Norway and roof rats depredate emergent hatchlings as they crawl from
the nest to the ocean at night, when the rats are most active. The Sea Turtle Recovery Plans stipulate that
predators should be removed from turtle nesting beaches to protected species listed under the authority of
the Endangered Species Act.

The proposed action would not adversely impact any federally listed threatened or endangered species or
Territorially listed endangered or rare species. The baits used would not produce secondary toxicity, and
the trapping methods used would not entrap any threatened or endangered species (Campbell 1989, Conry
1994, Witmer et. al. 1998).




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Vegetation Impacts
Native flora would be enhanced under this alternative because fewer rats would consume less vegetation.
This is particularly important in the dry season, when bark and leaves are consumed for their moisture
content. Also, fewer seeds from exotic plant species would be dispersed in fecal matter and in burrows.

Wildlife Impacts
The non-native rat population, estimated at from 2,000 to 2,400 individual animals, would be removed
from the Park over a one or two year period. Wildlife impacts would be positively affected by this action
because very large numbers of native fauna including several native bird, reptile and amphibian species
and numerous insect and spider species would benefit when the Norway and roof rat populations are kept
low. In addition, five native bat species, the only indigenous mammals on the island, would benefit from
reduced predation. Many bird, three bat and one reptile species are Locally Endangered by the
Government of the U.S. Virgin Islands.

Because herptafauna and invertebrates are small, often slow and readily available, they are particularly
susceptible to local extinction from rat depredation. 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.
Non-native rats prey upon three species of tree frogs, two geckos, three Anolis lizards, the Ground Lizard,
Legless Lizard, Blind Snake, the Puerto Rican Racer, and the Slipperyback Skink. The Park has listed
over 232 common insect species, including 13 species of dragonflies and damselflies and over 1500
beetle species, many of which are preyed upon by rats.

Water Quality Impacts
No adverse water quality impacts would be expected under this alternative.

Wetlands/Floodplain Impacts
Wetlands and floodplains impacts would be positively affected under this alternative. More native flora
and fauna would exist in and adjacent to these areas as foraging and predation pressure from non-native
rats decrease.

Park Operations Impacts
Lowest potential for adverse operational affects because non-native Norway and roof rat populations
would be greatly reduced throughout the Park at all visitor use, administrative, cultural and natural
resources sites. Under this alternative, the overall costs of administration of the non-native wildlife
control program would be increased with the implementation of contracts to remove exotic wildlife
($30,000 with the U.S. Department of Agriculture's Animal Plant Health Inspection Service / Wildlife
Services Division), purchase and installation of animal-proof trash receptacles and garbage cans, animal-
proofing park and concessionaire structures, and construction of fences to exclude non-native animals
from some developed areas.

Cumulative Impacts
The cumulative impacts from this alternative would have very positive consequences for National Park
Service lands, wildlife and marine waters. Every native terrestrial plant, animal and invertebrate species
would be positively impacted under this alternative. The greatest impact would be recovery of native
animal and plant species communities and the associated changes in native fauna, including birds, bats,
tree frogs and insect species. Serious negative impacts to the listed species including the Endangered
Brown Pelicans, Least Tems, Hawksbill and Leatherback sea turtles, Threatened Roseate Tems, and
Territorial Endangered species such as the Bridled Quail Dove, Bahama Pintail Duck and Antillean
Mango Hummingbird, would be greatly reduced or eliminated.


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Some visitors would see live traps and would then have the opportunity to ask questions and learn about
wildlife remediation efforts and their importance to small sensitive ecosystems. Wildlife control programs
in St. John mirror similar programs throughout the world. Visitors would be afforded the opportunity to
experience an U.S. National Park actively protecting the wildlife and habitat for which it was founded to
preserve for future generations. These are all extremely favorable, transferable and global aspects of this
wildlife control alternative.

Fewer non-native rats would disperse less disease causing organisms in tents, on picnic tables, in
restrooms and bathing facilities. A residual rat population may remain due to the difficulties in removing
100% of the population; however, NPS does not intend to maintain a residual population. Implementing
this reduction program should result in rats that avoid human habitations in both day and night time.

The Park's recently approved Commercial Services Plan/Final EA (2001) identified the need to establish
a new mobile unit food services operation at Hawksnest Bay and new commercial services contracts for
Trunk Bay and Cinnamon Bay Campground concessions. An integrated pest management approach
would be included in any contract language that minimizes the adverse affects of non-native rats on Park
facilities, daily concession operations and public safety.

This favorably affects and is, therefore, consistent with the approved Coastal Zone Management Plan that
supports the removal of non-native pests that damage the coastal zone and wildlife therein, and policies of
the Territory of the U. S. Virgin Islands.


IV.B. Non-native Cat Control

IV.B.1. Alternative 3. No Action, Continue Current Level of Management

Air Quality Impacts
No adverse air quality impacts would be expected under this alternative.

Scenic Values
Scenic values would decline under this alternative as the native flora and fauna species depredated by
non-native cat's decrease in number because cats would continue to eat many types of wildlife that the
public hopes to see during a visit to VINP. The aesthetics near dumpsters would decline and trash would
be scattered into the bush and nearby roadsides. The sight of viewing cats on picnic tables or starving and
begging for food in and around centers of human activity and along roadsides would increase. The
natural and cultural resource values of the island would decrease.

Cultural Resource Impacts
No adverse cultural resource impacts would be expected under this alternative.

Socioeconomic/Visitor Use Impacts
Tourism may slightly decrease, especially ovemight stays, under this alternative. Visitor experiences
would decline because they may visit fewer sites and stay shorter periods if they have negative impacts at
the sites. This is especially true if people experience starving, emaciated and begging non-native cats at
several areas within the Park. Increases of cat transmitted disease among visitors could affect visitation
and visitor experience.



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SUSTAINED REDUCTION NON-NATIVE RATS, CATS & MONGOOSES ENVIRONMENTAL ASSESSMENT
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Soil Impacts
No adverse soil impacts would be expected under this alternative.

Threatened and Endangered Species Impacts
Non-native cats were identified as a potential threat to each of the Federally or Territorially listed
Endangered and Threatened (T&E) plant and animal species found on St. John Island. Under this
alternative, the threats to each of the listed species would remain. Cats would continue to predate listed
species. The listed species include the Endangered Brown Pelican, Least Ter and Hawksbill Turtle, and
Threatened Roseate Ter and Green Turtle.

Cats also depredate four (of the five) native bat species, three of which are Territorially endangered, and
the only indigenous mammals on the island. Other Territorial endangered species include ground and tree
nesting species such as Bridled Quail Dove, Bahama Pintail Duck and Antillean Mango Hummingbird,
all of which suffer egg and chick depredation due to cats.

Vegetation Impacts
There would be no change in the type or level of impacts to native vegetation under this alternative.

Wildlife Impacts
The non-native cat population, estimated at from 15 to 30 individual animals, would continue to fluctuate
due to annual differences in weather. Native wildlife would to be adversely impacted by this action
because cats depredate very large numbers of native fauna including several native bird, reptile and
amphibian species and numerous insect and spider species. Because herptofauna and invertebrates are
small, often slow and readily available, they are particularly susceptible to local extinction from cat
depredation. 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.

Cats prey upon three species of tree frogs, two geckos, three Anolis lizards, the Ground Lizard, Legless
Lizard, Blind Snake, the Puerto Rican Racer, and the Slipperyback Skink. The Park has listed over 232
common insect species, including 13 species of dragonflies and damselflies and over 1500 beetle species,
many of which are preyed upon by cats. Many invertebrate species may be lost before researchers have
catalogued them.

Cats routinely kill insects and other small animals for sport, play, pleasure, practice or for no apparent
reason, in addition to using them as a food source, therefore great numbers of wildlife are lost each year
to a small non-native cat population. Both the cumulative impact and the secondary and tertiary impacts
associated with this great and increasing wildlife loss is of huge importance. Small islands tend to have
both smaller resident wildlife populations and lower species diversity. To exacerbate matters, cats
depredate a wide range of fauna, including ground, bush and tree-nesting birds and waterfowl, every
native species of reptile, amphibian, mammal and literally hundreds of invertebrate species. These
problems are particularly problematic 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.

Water Quality Impacts
No adverse water quality impacts would be expected under this alternative.

Wetlands/Floodplain Impacts
Adverse impacts to wetlands, mainly salt ponds, and would continue under this alternative as the native
flora and fauna continue to change under the foraging and predation pressure of non-native cats

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SUSTAINED REDUCTION NON-NATIVE RATS, CATS & MONGOOSES ENVIRONMENTAL ASSESSMENT
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throughout the Park. This is especially problematic where salt ponds occur near centers of human
activities, e.g. Annaberg Sugar Plantation. Cats using wetland habitats routinely kill insects and other
small native animals for food; therefore great numbers of wildlife are lost each year to a snall cat
population. Cats depredate a wide range of fauna, including ground-nesting birds, waterfowl, and every
native species of reptile, amphibian, and literally hundreds of invertebrate species using wetlands and
floodplain habitats.

Park Operations Impacts
Highest potential for adverse operational affects from non-native cats on the Park's administrative,
resources management, interpretation, law enforcement and maintenance costs would be expected to
continue. Under this alternative, NPS would continue to animal-proof trash receptacles and dumpsters at
campgrounds, day use sites, concession areas, park overlooks, and employee housing areas. During the
last year, Virgin Islands NP has purchased and installed over 50 pre-manufactured animal-proof trash
containers (at a cost of about $75,000) at all Park sites except at the major concession operations at Trunk
Bay and Cinnamon Bay to collect both refuse and recyclables. In fiscal year 2002, the NPS requested
$30,000 in funding to purchase and install an additional 20 pre-manufactured animal-proof trash
containers at major concession operations (eight at Trunk Bay and twelve at Cinnamon Bay) to collect
both refuse and recyclables. Also in 2002, NPS has contracted for the construction of a donkey-exclusion
fence with four barbed-wire strands around the perimeter of the Cinnamon Bay Campground at an
estimated cost of $67,000.

Cumulative Impacts
The cumulative impacts from this alternative would have severe negative consequences for National Park
Service lands and wildlife. Almost every native terrestrial plant, animal and invertebrate species would be
adversely impacted under this alternative. The greatest impact would be changes in plant species
composition and the associated changes in native fauna, including birds, bats, tree frogs and insect
species. Eventually, many species would become locally extinct, some before they are even identified by
researchers.

Health and sanitation conditions would not be mitigated under this action. Health and sanitation impacts
would continue to decline under this action. More non-native cats would disperse more disease causing
organisms in more places, including tents, picnic tables, sinks and bathing facilities. Some people may
choose not to visit St. John as the result, and those who do may reduce their stay and have a negative
experience. This is certainly true when visitors' view emaciated cats on picnic tables, along roadsides and
begging from scenic overlooks, premiere cultural sites and every public activity center they visit.

Moreover, the Park offers visitors a negative interpretative message, which highlights the problems
encountered when non-native species are not managed. And the Park fails to protect the natural resources for
enjoyment of future generations; the fundamental premise for which the Virgin Islands National Park was
founded.

This alternative adversely affects approved Coastal Zone Management Plan that supports the removal of
non-native pests that damage the coastal zone and wildlife therein, and policies of the Virgin Islands for
reasons described above. The National Park Service has, therefore, determined that the program is
inconsistent with the Coastal Zone Management Plan of the Territory of the U. S. Virgin Islands.






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IV.B.2. Alternative 4. Proposed Action Sustained Reduction

Air Quality Impacts
No adverse air quality impacts would be expected under this alternative.

Scenic Values
Scenic values are enhanced under this alternative as the native faunal species previously cbpredated by
non-native cats' increase, resulting in more native fauna sightings because cats would no longer continue
to eat many types of wildlife that the public hopes to see during a visit to VINP. The aesthetic
environment near dumpsters may be enhanced as trash being pulled out of the dumpsters by cats is
reduced or eliminated. The natural and cultural resources values of the island would greatly increase.

Cultural Resource Impacts
No adverse cultural resource impacts would be expected under this alternative.

Socioeconomic/Visitor Use Impacts
Visitor use patterns should be enhanced with a possible tourism increase under this alternative. Potential
visitors who opted to vacation in another area as the result of media coverage or word-of-mouth
communication about cat transmitted disease problems may visit when the vector for these diseases is
removed. The tourist experience, especially at Trunk Bay, Francis Bay and Cinnamon Bay Camps, Inc,
for example, would be safer, healthier, and improved.

Soil Impacts
No adverse soil impacts would be expected under this alternative.

Threatened and Endangered Species Impacts
Under Alternative Four, non-native cats would be quickly reduced as a threat to each of the Federally or
Territorially listed Endangered and Threatened (T&E) plant and animal species found on St. John Island.
Under this alternative, the threats to each of the listed species would be completely eliminated by the
sustained reduction program. Cats depredate chicks, juveniles and adults of all birds nesting on St. John.
Of particular concern is depredation to Endangered Brown Pelicans (Pelecanus occidentalis) and Least
Terns (Sterna antillarum), and the Threatened Roseatte Tems (Sterna dougallii). Cats may also predate
hatchlings sea turtles, Hawksbill and Green, as they travel from nest to the sea at night.

Cats also may depredate four (of the five) native bat species, three of which are Territorially Endangered,
and the only indigenous mammals on the island. Other Territorial endangered species include ground and
tree nesting species such as Bridled Quail Dove, Bahama Pintail Duck and Antillean Mango
Hummingbird, all of which suffer egg and chick depredation due to cats. The Sea Turtle Recovery Plans
stipulate that predators should be removed from nesting sites.

The proposed action would not adversely impact any federally listed threatened or endangered species
here or Territorially listed endangered or rare species. The food baits used would not produce secondary
toxicity, and the trapping methods used would not entrap any threatened or endangered species (Campbell
1989, Conry 1994, and Witmer et. al. 1998).

Vegetation Impacts
There would be no change in the type or level of impacts to native vegetation under this alternative.




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Wildlife Impacts
The non-native cat population, estimated at from 15 to 30 individual animals, would be removed from the
Park over a one or two year period. Wildlife impacts would be positively mitigated by this action because
very large numbers of native fauna including several native bird, reptile and amphibian species and
numerous insect and spider species would benefit when cat populations are kept low. In addition, five
native bat species, the only indigenous mammals on the island, would benefit from reduced predation.

Because herptofauna and invertebrates are small, often slow and readily available, they are particularly
susceptible to local extinction from cat depredation. 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.
Non-native cats prey upon three species of tree frogs, two geckos, three Anolis lizards, the Ground
Lizard, Legless Lizard, Blind Snake, the Puerto Rican Racer, and the Slipperyback Skink. The Park has
listed over 232 common insect species, including 13 species of dragonflies and damselflies and over 1500
beetle species, many of which are preyed upon by cats.

Cats routinely kill insects and other small animals for sport, play, pleasure, practice or for no apparent
reason, in addition to using them as a food source, therefore, great numbers of wildlife are lost each year
to a small non-native cat population. Both the cumulative impact and the secondary impacts associated
with these increasing wildlife loses are of huge importance. Small islands tend to 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.

Water Quality Impacts
No adverse water quality impacts would be expected under this alternative.

Wetlands/Floodplain Impacts
Wetlands and floodplains impacts would be positively affected under this alternative. More native flora
and fauna would exist in and adjacent to these areas as foraging and predation pressure from non-native
cats decrease because cats would not longer be preying upon wildlife species that live in these wetland
habitats. Cats using wetland habitats routinely kill insects and other small native animals for food;
therefore great numbers of wildlife are lost each year to a small cat population. Cats depredate a wide
range of fauna, including ground-nesting birds, waterfowl, and every native species of reptile, amphibian,
and literally hundreds of invertebrate species using wetlands and floodplain habitats.

Park Operations Impacts
Lowest potential for adverse operational affects because non-native cat populations would be greatly
reduced throughout the Park at all visitor use, administrative, cultural and natural resources sites. Under
this alternative, the overall costs of administration of the non-native wildlife control program would be
increased with the implementation of contracts to remove exotic wildlife ($30,000 with the U.S.
Department of Agriculture's Animal Plant Health Inspection Service / Wildlife Services Division),
purchase and installation of animal-proof trash receptacles and garbage cans, animal-proofing park and
concessionaire structures, and construction of fences to exclude non-native animals from some developed
areas.

Cumulative Impacts
The cumulative impacts from this alternative would have very positive consequences for National Park
Service lands, wildlife and marine waters. Every native terrestrial plant, animal and invertebrate species
would be positively impacted under this alternative. The greatest impact would be recovery of native
animal and plant species communities and the associated changes in native fauna, including birds, bats,

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SUSTAINED REDUCTION NON-NATIVE RATS, CATS & MONGOOSES ENVIRONMENTAL ASSESSMENT
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tree frogs and insect species. Serious negative impacts to the listed species including the Endangered
Brown Pelicans, Least Terns, Hawksbill and Leatherback sea turtles, Threatened Roseate Terns, and
Territorial Endangered species such as the Bridled Quail Dove, Bahama Pintail Duck and Antillean
Mango Hummingbird, would be greatly reduced or eliminated.

Some visitors would see live traps and would then have the opportunity to ask questions and learn about
wildlife remediation efforts and their importance to small sensitive ecosystems. Wildlife control
programs in St. John mirror similar programs throughout the world. Visitors would be afforded the
opportunity to experience an U.S. National Park actively protecting the wildlife and habitat for which it
was founded to preserve for future generations. These are all extremely favorable, transferable and global
aspects of this wildlife control alternative.

Fewer non-native cats would disperse less disease causing organisms in tents, on picnic tables, in
restrooms and bathing facilities. A very small residual cat population may remain due to the difficulties
in removing 100% of the population; however, NPS does not intend to maintain a residual population.
Implementing this reduction program should result in cats that avoid human habitations in both day and
night time. New cats are expected to occasionally enter centers of human activity and these would be
promptly trapped and removed.

The Park's recently approved Commercial Services Plan/Final EA (2001) identified the need to establish
a new mobile unit food services operation at Hawksnest Bay and new commercial services contracts for
Trunk Bay and Cinnamon Bay Campground concessions. An integrated pest management approach
would be included in any contract language that minimizes the adverse affects of non-native cats on Park
facilities, daily concession operations and public safety.

This favorably affects and is, therefore, consistent with the approved Coastal Zone Management Plan that
supports the removal of non-native pests that damage the coastal zone and wildlife therein, and policies of
the Territory of the U. S. Virgin Islands.


IV.C. Non-native Mongoose Control

IV.C.1. Alternative 5. No Action, Continue Current Level of Management

Air Quality Impacts
No adverse air quality impacts would be expected under this alternative.

Scenic Values
Scenic values would decline under this alternative as the native faunal species depredated by non-native
mongooses continue to decrease in numbers because mongooses would continue to eat many types of
wildlife that the public hopes to see during a visit to VINP. The aesthetics near dumpsters would decline
and trash would be scattered into the bush and nearby roadside. The natural and cultural resource values
of the island would decrease.

Cultural Resource Impacts
Non-native mongooses would continue to damage irreplaceable archeological and hstorical sites and
would degrade the scientific importance of the St. John Archeological District. Under this alternative,
damage to archeological and historic sites by mongooses would continue essentially unabated. Cultural


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SUSTAINED REDUCTION NON-NATIVE RATS, CATS & MONGOOSES ENVIRONMENTAL ASSESSMENT
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resource impacts would remain the same at historic sugar plantations throughout the Park under this
alternative.

Socioeconomic/Visitor Use Impacts
Tourism may decrease slightly under this alternative. Visitor experiences would decline because they may
visit fewer sites and stay shorter periods if they have negative experiences at the sites. This is especially
true if people experience non-native mongooses at several sites during their visit, including picnic
tabletops, in and around sleeping quarters and dumpsters. Moreover, the ear-piercing aggressive
screeching sound offered by many frightened adult mongooses, as warming of danger to other mongooses
can be frightening.

Soil Impacts
No adverse soil impacts would be expected under this alternative.

Threatened and Endangered Species Impacts
Non-native mongooses were identified as a potential threat to each of the Federally or Territorially listed
Endangered and Threatened (T&E) plant and animal species found on St. John Island. Under this
alternative, the threats to each of the listed species would remain. Mongoose would continue to predate
listed species. The listed species include the Endangered Hawksbill and Leatherback sea turtles,
Endangered Brown Pelicans and Least Tems, and Threatened Roseate Terns.

Mongooses also depredate four (of the five) native bat species, three of which are Territorially
Endangered, and the only indigenous mammals on the island. Other Territorial Endangered species
include ground and tree nesting species such as Bridled Quail Dove, Bahama Pintail Duck and Antillean
Mango Hummingbird, all of which suffer egg and chick depredation due to non-native mongoose.

Vegetation Impacts
Under this alternative, no eradication efforts would be used on non-native mongooses on St. John Island.
Their population numbers would continue to rise and fall with the seasonal and long-term availability of
food resources. There would be no change in the type or level of impacts to native vegetation under this
alternative. This is particularly important in the dry season, when fruit from non-native tree species are
sometimes consumed for their moisture content. This can result in more seeds from exotic plant species
being dispersed in fecal matter. This complex ecological problem is exacerbated over time as the
accumulative affects multiply and have a greater influence on the vegetation island-wide, as well as the
fauna and small ecosystems found within the vegetation.

Wildlife Impacts
The non-native mongoose population, estimated at from 300 to 400 individual animals, would continue to
fluctuate due to annual differences in weather. Native wildlife would be adversely impacted by this
action because mongooses depredate very large numbers of native fauna including several native bird,
reptile and amphibian species and numerous insect and spider species.

Because herptofauna and invertebrates are small, often slow and readily available, they are particularly
susceptible to local extinction from mongoose depredation. 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.

Mongoose prey upon three species of tree frogs, two geckos, three Anolis lizards, the Ground Lizard,
Legless Lizard, Blind Snake, the Puerto Rican Racer, and the Slipperyback Skink. The Park has listed
over 232 common insect species, including 13 species of dragonflies and damselflies and over 1500

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beetle species, many of which are preyed upon by non-native mongooses. Many invertebrate species may
be lost before researchers have even catalogued them.

Both the accumulative impact and the secondary ecological impacts associated with these increasing
wildlife loses are of huge importance. Small islands tend to have both smaller resident wildlife
populations and lower species diversity. To exacerbate matters, mongooses depredate a wide range of
fauna, including ground and shrub-nesting birds and waterfowl, every native species of reptile and
amphibian and literally hundreds of invertebrate species. These problems are particularly problematic on
very small and highly fragmented islands such as St. John, because most negative impacts are
concentrated and magnified when compared with similar impacts to a larger landmass.

Water Quality Impacts
No adverse water quality impacts would be expected under this alternative.

Wetlands/Floodplain Impacts
Adverse impacts to wetlands, mainly saltponds, would continue under this alternative as the native flora
and fauna continue to change under the foraging and predation pressure of non-native mongooses
throughout the Park decrease because mongoose would not longer be preying upon wildlife species that
live in these wetland habitats. This is especially problematic where salt ponds occur near centers of
human activities, e.g. Annaberg Sugar Plantation, Francis Bay, etc.

Park Operations Impacts
Highest potential for adverse operational affects from non-native mongooses on the Park's administrative,
resources management, interpretation, law enforcement and maintenance costs would be expected to
continue. Under this alternative, NPS would continue to animal-proof trash receptacles and dumpsters at
campgrounds, day use sites, concession areas, park overlooks, and employee housing areas. During the
last year, Virgin Islands NP has purchased and installed over 50 pre-manufactured animal-proof trash
containers (at a cost of about $75,000) at all Park sites except at the major concession operations at Trunk
Bay and Cinnamon Bay to collect both refuse and recyclables. In fiscal year 2002, the NPS requested
$30,000 in funding to purchase and install an additional 20 pre-manufactured animal-proof trash
containers at major concession operations (eight at Trunk Bay and twelve at Cinnamon Bay) to collect
both refuse and recyclables. Also in 2002, NPS has contracted for the construction of a donkey-exclusion
fence with four barbed-wire strands around the perimeter of the Cinnamon Bay Campground at an
estimated cost of $67,000.

Cumulative Impacts
The cumulative impacts from this alternative would have severe negative consequences for National Park
Service lands and wildlife. Almost every native terrestrial plant, animal and invertebrate species would
be adversely impacted under this alternative. The greatest impact would be changes in wildlife species
composition and the associated changes in native flora. Eventually, many species would become locally
extinct, many before they are even identified by researchers.

Health and sanitation conditions would not be mitigated under this action. Health and sanitation impacts
would continue to decline under this action. More non-native mongooses could potentially disperse more
disease causing organisms in more places, including tents, picnic tables, sinks and bathing facilities.
Some people may choose not to visit St. John as a result, and those who do may reduce their stay and
have a negative experience. This is certainly true as mongoose's forage for food in the daytime.

Moreover, the Park offers visitors a negative interpretative message that highlights the problems encountered
when non-native species are not managed. In addition, the Park fails to protect the natural resources for

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enjoyment of future generations; the fundamental premise for which the Virgin Islands National Park was
founded.

This alternative adversely affects approved Coastal Zone Management Plan that supports the removal of
non-native pests that damage the coastal zone and wildlife therein, and policies of the Virgin Islands for
reasons described above. The National Park Service has, therefore, determined that the proposed action is
inconsistent with the Coastal Zone Management Plan of the Territory of the U. S. Virgin Islands.


IV.C.2. Alternative 6. Proposed Action Sustained Reduction

Air Quality Impacts
No adverse air quality impacts would be expected under this alternative.

Scenic Values
Scenic values would be enhanced under this alternative as the native faunal species depredated by non-
native mongoose's increase in numbers, resulting in more native faunal sightings because mongooses
would no longer continue to eat many types of wildlife that the public hopes to see during a visit to VINP.
The aesthetic environment near dumpsters would be enhanced when trash and food wastes are not seen
and offensive odors are reduced. The natural and cultural resources values of the island would greatly
increase.

Cultural Resource Impacts
No adverse cultural resource impacts would be expected under this alternative.

Socioeconomic/Visitor Use Impacts
Visitor use patterns should be enhanced under this alternative as non-native mongooses no longer steal or
damage food items belonging to campers or picnickers. Fewer mongooses would disperse less disease
causing organisms in tents, on picnic tables, in restrooms and bathing facilities. Reducing the "residual"
mongoose population level should result in mongooses that avoid human habitations and activity centers.

Soil Impacts
No adverse soil impacts would be expected under this alternative.

Threatened and Endangered Species Impacts
Under Alternative Six, non-native mongoose would be quickly reduced as a threat to each of the
Federally or Territorially listed Endangered and Threatened (T&E) plant and animal species found on St.
John Island. Under this alternative, the threats to each of the listed species would be completely
eliminated by the sustained reduction program. Mongooses are often primary predators of Endangered
Hawksbill (Eretmochelys imbricata) and Leatherback (Dermochelys coriacea) sea turtles and Threatened
Green (Chelonia mydas) sea turtles that nest on the island (Nellis and Small 1983; Boulon 1999).
Mongooses would depredate sea turtle nests soon after being laid when the odor is still present, eating
many eggs and spoiling the remaining ones. They would also predate a nest just before or immediately
after hatching as the emergent hatchling crawl from the nest to the ocean in the early morning hours,
when mongooses begin to hunt. Often, hatchlings trickle from their nesting cavity over a period of
several hours, leaving them susceptible to mongoose predation in the daytime. Often, mongooses
depredating sea turtle nests enter a "feeding frenzy" behavior, during which they kill and maim every sea
turtle, while eating just a small number. The Sea Turtle Recovery Plans stipulate that predators should be
removed from turtle nesting beaches.

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SUSTAINED REDUCTION NON-NATIVE RATS, CATS & MONGOOSES ENVIRONMENTAL ASSESSMENT
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Territorial endangered species depredated by mongooses include ground and tree nesting species such as
Bridled Quail Dove and Bahama Pintail Duck, both of which suffer egg and chick depredation due to
non-native mongooses.

The proposed action would not adversely impact any federally listed threatened or endangered species or
Territorially listed endangered or rare species. The food baits used would not produce secondary toxicity,
and the trapping methods used would not entrap any threatened or endangered species (Campbell 1989,
Conry 1994, Witmer et. al. 1998).

Vegetation Impacts
There would be no change in the type or level of impacts to native vegetation under this alternative.

Wildlife Impacts
The non-native mongoose population, estimated at from 300 to 400 individual animals, would be
removed from the Park over a one or two year period. Wildlife impacts would be positively mitigated by
this action because very large numbers of native fauna including several native bird species would benefit
when mongoose populations are kept low. Mongooses depredate eggs, chicks or adults from shorebird,
waterfowl and other birds nesting on or near the ground. Likewise, numerous species of reptiles would
benefit from reduction of mongoose populations because mongooses would no longer be preying upon
eggs, young and adults.

Water Quality Impacts
No adverse water quality impacts would be expected under this alternative.

Wetlands/Floodplain Impacts
Wetlands and floodplains impacts would be positively affected under this alternative. More native flora
and fauna would exist in and adjacent to these areas as foraging and predation pressure from non-native
mongoose decrease because mongooses would not longer be preying upon wildlife species that live in
these wetland habitats.

Park Operations Impacts
Lowest potential for adverse operational affects because non-native mongoose populations would be
greatly reduced throughout the Park at all visitor use, administrative, cultural and natural resources sites.
Under this alternative, the overall costs of administration of the non-native wildlife control program
would be increased with the implementation of contracts to remove exotic wildlife ($30,000 with the U.S.
Department of Agriculture's Animal Plant Health Inspection Service / Wildlife Services Division),
purchase and installation of animal-proof trash receptacles and garbage cans, animal-proofing park and
concessionaire structures, and construction of fences to exclude non-native animals from some developed
areas.

Cumulative Impacts
The cumulative impacts from this alternative would have very positive consequences for National Park
Service lands, wildlife and marine waters. Every native terrestrial plant, animal and invertebrate species
would be positively impacted under this alternative. The greatest impact would be recovery of native
animal and plant species communities and the associated changes in native fauna, including birds, bats,
tree frogs and insect species. Serious negative impacts to the listed species including the Endangered
Brown Pelicans, Least Tems, Hawksbill and Leatherback sea turtles, Threatened Roseate Tems, and
Territorial Endangered species such as the Bridled Quail Dove, Bahama Pintail Duck and Antillean
Mango Hummingbird, would be greatly reduced or eliminated.


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SUSTAINED REDUCTION NON-NATIVE RATS, CATS & MONGOOSES ENVIRONMENTAL ASSESSMENT
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Some visitors would see live traps and would then have the opportunity to ask questions and learn about
wildlife remediation efforts and their importance to small sensitive ecosystems. Wildlife control programs
in St. John mirror similar programs throughout the world. Visitors would be afforded the opportunity to
experience an U.S. National Park actively protecting the wildlife and habitat for which it was founded to
preserve for future generations. These are all extremely favorable, transferable and global aspects of this
wildlife control alternative.

Fewer non-native mongooses would disperse less disease causing organisms in tents, on picnic tables, in
restrooms and bathing facilities. A small residual mongoose population may remain due to the
difficulties in removing 100% of the population; however, NPS does not intend to maintain a residual
population. Implementing this reduction program should result in mongooses that avoid human
habitations in both day and night time.

The Park's recently approved Commercial Services Plan/Final EA (2001) identified the need to establish
a new mobile unit food services operation at Hawksnest Bay and new commercial services contracts for
Trunk Bay and Cinnamon Bay Campground concessions. An integrated pest management approach
would be included in any contract language that minimizes the adverse affects of non-native mongooses
on Park facilities, daily concession operations and public safety.

This favorably affects and is, therefore, consistent with the approved Coastal Zone Management Plan that
supports the removal of non-native pests that damage the coastal zone and wildlife therein, and policies of
the Territory of the U. S. Virgin Islands.































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SUSTAINED REDUCTION NON-NATIVE RATS, CATS & MONGOOSES ENVIRONMENTAL ASSESSMENT
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IV.D. Comparison of Alternatives


This section describes the alternatives that were analyzed in this environmental assessment for non-native
rat, cat, and mongoose control in Virgin Islands National Park. The alternatives include no action (1, 3
and 5), and the proposed actions sustained reduction (2, 4 and 6).



Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5 Alternative 6
IA.A2 ILA3 RB.2 I1.B.3 .C.2 II.C.3
Impact Non-native Non-native Non-native Non-native Non-native Non-native
Category Rats Control Rats Control Cats Control Cats Control Mongooses Mongooses
Control Control

Proposed Proposed Proposed
No Action Action No Action Action No Action Action

Air Quality No adverse Same as Same as Same as Same as Same as
impacts would be Alternative 1. Alternative 1. Alternative 1. Alternative 1. Alternative 1.
Impacts expected.


Scenic Values Highest potential Lowest potential for Highest potential Lowest potential Highest potential Lowest potential
for adverse adverse impacts as for adverse impacts for adverse impacts for adverse impacts for adverse impacts
impacts as trash is trash is not widely as trash is widely as trash is not as trash is widely as trash is not
widely scattered scattered. Food scattered and cats widely scattered. scattered and widely scattered.
and rats kill native wastes are not seen kill native flora and Food wastes are not mongooses kill Food wastes are not
flora and fauna. and offensive odors fauna. seen and offensive native flora and seen and offensive
are reduced. odors are reduced. fauna. odors are reduced.


Cultural Highest potential Lowest potential for Cultural resource Cultural resource Highest potential Lowest potential
for adverse adverse impacts as impacts would impacts would for adverse impacts for adverse impacts
Resources impacts as burrowing, remain unchanged. remain unchanged. as burrowing, as burrowing,
Impacts burrowing, vegetation grazing vegetation grazing vegetation grazing
vegetation grazing and seed dispersal and seed dispersal and seed dispersal
and seed dispersal caused by rats would continually caused by
would continually would be greatly undermine historic mongooses would
undermine historic reduced. This would structures. Fecal be greatly reduced.
structures. Fecal result in safer, and urine This would result in
and urine cleaner, healthier contamination safer, cleaner,
contamination and more stable would continue healthier and more
would continue structures for unabated. stable structures for
unabated. interpretation and interpretation and
enjoyment. enjoyment.


Socio- Tourism may Tourism would be Tourism may Tourism would be Tourism may Tourism would be
decrease slightly enhanced at all Park slightly decrease, enhanced at all decrease slightly at enhanced at all
economic/ as all Park sites sites since visitors especially Park sites, all Park sites if the Park sites as
Visitor Use would continue to would no longer be overnight stays, if especially at Trunk public would mongooses would
Impacts be adversely adversely impacted people experience Bay, Francis Bay continue to be no longer steal or
impacted by rats by rats entering starving, emaciated and Cinnamon Bay adversely impacted damage food items
entering tents, tents, eating food and begging cats at Camps, Inc. The by mongooses belonging to
eating food and and other items and several Park sites. public would no entering tents, campers or
other items and depositing fecal Increases in cat longer experience eating food and picnickers.
depositing fecal materials on transmitted disease starving, emaciated other items and
materials on personal belongings, among visitors and begging cats at depositing fecal
personal The visitor would affect use these sites. The materials on
belongings, experience would be levels and the visitor experience personal
greatly improved, quality of the would be much belongings.
visitor experience, safer, healthier and
improved.

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SUSTAINED REDUCTION NON-NATIVE RATS, CATS & MONGOOSES ENVIRONMENTAL ASSESSMENT
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Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5 Alternative 6
ILA.2 ILA3 IB.2 RB.3 .C.2 II.C.3
Impact Non-native Non-native Non-native Non-native Non-native Non-native
Category Rats Control Rats Control Cats Control Cats Control Mongooses Mongooses
Control Control


Proposed Proposed Proposed
No Action Action No Action Action No Action Action

Soil Impacts Highest potential Lowest potential for No adverse impacts No adverse impacts No adverse impacts No adverse impacts
for adverse affects adverse impacts as would be expected. would be expected. would be expected. would be expected.
as increased decreased tunneling
tunneling within, and fewer tunnels
under and adjacent would increase the
to historic or stability of historic
modern structures or modern
could decrease structures. Fewer
their stability. tunnels within seeds
More tunnels are transported
within which seeds would no longer
are transported undermine the
would undermine stability and
the stability and integrity of all
integrity of all buildings and
buildings and especially the
especially the cultural landscape.
cultural landscape.



Vegetation Highest potential Lowest potential for No adverse impacts No adverse impacts Highest potential Lowest potential
for adverse affects adverse impacts would be expected. would be expected. for adverse affects for adverse impacts
Impacts from rats in the because fewer rats Impacts to native Impacts to native from mongooses in because fewer
Park would be would consume less vegetation would vegetation would the Park would be mongooses would
continuing impacts native flora and remain unchanged remain unchanged continuing impacts consume native
to native enhance because under this under this to native vegetation flora. Native
vegetation. This is fewer rats would alternative, alternative. This is particularly vegetation impacts
particularly consume less important in thedry remain unchanged
important in the vegetation. This is season, when fruit under this
dry season, when particularly from non-native alternative.
bark and leaves are important in the dry tree species are
consumed for their season, when bark sometimes
moisture content. and leaves are consumed for their
In addition, fewer consumed for their moisture content.
seeds from non- moisture content. This can result in
native plant Also, fewer seeds more seeds from
species would be from non-native non-native plant
dispersed in fecal plant species would species being
matter and in be dispersed in fecal dispersed in fecal
burrows. This matter and in matter. This
complex burrows. complex ecological
ecological problem problem is
is exacerbated over exacerbated over
time as the time as the
accumulative accumulative
affects multiply affects multiply and
and have a greater have a greater
influence on the influence on the
vegetation island- vegetation island-
wide, as well as wide, as well as the
the fauna and fauna and small
micro-habitats ecosystems found
found within the within the
vegetation, vegetation.




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Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5 Alternative 6
ILA.2 ILA3 IB.2 RB.3 .C.2 II.C.3

Impact Non-native Non-native Non-native Non-native Non-native Non-native

Category Rats Control Rats Control Cats Control Cats Control Mongooses Mongooses
Control Control


Proposed Proposed Proposed
No Action Action No Action Action No Action Action


Threatened/
Endangered
Species
Impacts


Highest potential
for adverse affects
since the Park
would be not be
protecting listed
Endangered
Species Act (ESA)
species by failing
to actively remove
or destroy species
that are known to
predate listed
species. In St.
John the listed
species include the
Endangered
Hawksbill and
Leatherback sea
turtles,
Endangered Brown
Pelicans and Least
Terns, and
Threatened
Roseate Terns.

Rats also
depredate four (of
the five) native bat
species, three of
which are
Territorially
Endangered, and
the only
indigenous
mammals on the
island. Other
Territorial
Endangered
species include
ground and tree
nesting species
such as Bridled
Quail Dove,
Bahama Pintail
duck and Antillean
Mango
hummingbird, all
of which suffer
egg and chick
death due to rats.


Lowest potential for
adverse affects
because Norway
and roof rats would
no longer be killing
the eggs or chicks
from all birds
nesting on St. John.
Of particular
concern is
depredation to
Endangered Brown
Pelicans, Least
Terns, and the
Threatened Roseate
Terns.

Territorial
endangered species
include ground
and tree nesting
species such as
Bridled Quail Dove,
Bahama Pintail
duck and Antillean
Mango
hummingbird, all of
which suffer egg
and chick
depredation due to
rats.

Rats are not primary
predators of
Endangered
Hawksbill and
Leatherback sea
turtles which nest
on the island,
however, rats are
involved in
predation events
each year. Both
Norway and roof
rats depredate
emergent hatchlings
as they crawl from
the nest to the ocean
at night, when the
rats are most active.
The sea turtle
recovery plans
stipulate that
predators should be
removed from turtle
nesting beaches.


Highest potential
for adverse affects
since the Park
would not be
protecting by
failing to actively
remove or destroy
species, which are
known to predate,
federally
Endangered
Species Act listed
species. On St.
John the listed
species include the
Endangered Brown
Pelican, Least Tern
and Hawksbill
turtle, and
Threatened Roseate
Tern and Green
turtle.

Cats also depredate
four (of the five)
native bat species,
three of which are
Territorially
endangered, and the
only indigenous
mammals on the
island.

Other Territorial
endangered species
include ground and
tree nesting species
such as Bridled
Quail Dove,
Bahama Pintail
duck and Antillean
Mango
hummingbird, all of
which suffer egg
and chick death to
cats.


Lowest potential
for adverse affects
because cats
depredate chicks,
juveniles and adults
of all birds nesting
on St. John. Of
particular concern
is depredation to
Endangered Brown
Pelicans, and Least
Terns, and the
Threatened
Roseatte Terns.

Cats may also
predate hatchlings
sea turtles,
Endangered
Hawksbill and
Green, as they
travel from nest to
the sea at night.

Cats also may
depredate four (of
the five) native bat
species, three of
which are
Territorially
Endangered, and
the only indigenous
mammals on the
island.

Other Territorial
endangered species
include ground and
tree nesting species
such as Bridled
Quail Dove,
Bahama Pintail
duck and Antillean
Mango
hummingbird, all of
which suffer egg
and chick death due
to cats. The
Endangered
Species Act
stipulates that
predators should be
removed from
nesting sites to
protect species
listed under the
ESA.


Highest potential
for adverse affects
since the Park
would be failing
to actively remove
or destroy species,
which are known to
predate, listed
Endangered
Species Act
species. In St. John
the listed species
include the
Endangered
Hawksbill and
Leatherback sea
turtles, Endangered
Brown Pelicans and
Least Terns, and
Threatened Roseate
Terns.

Territorial
endangered species
include ground and
tree nesting species
such as Bridled
Quail Dove and
Bahama Pintail
duck, both of which
suffer egg and
chick depredation
due to mongooses.


Lowest potential
for adverse affects
because mongooses
are often primary
predators of
Endangered
Hawksbill and,
Leatherback sea
turtles and
Threatened Green
sea turtles that nest
on the island.
Mongooses would
depredate sea turtle
nests soon after
being laid when the
odor is still present,
eating many eggs
and spoiling the
remaining ones.

They would also
predate a nest just
before or
immediately after
hatching as the
emergent
hatchlings crawl
from the nest to the
ocean in the early
morning hours,
when mongooses
begin to hunt.

Often, mongooses
depredating sea
turtle nests enter a
"feeding frenzy"
behavior, during
which they kill and
maim every sea
turtle, while eating
just a small
number. The sea
turtle recovery
plans stipulate that
predators should be
removed from
turtle nesting
beaches to protect
species listed under
the ESA


SUSTAINED REDUCTION NON-NATIVE RATS, CATS & MONGOOSES ENVIRONMENTAL ASSESSMENT
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MARCH 2002 FINAL












Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5 Alternative 6
IA.A2 ILA3 IB.2 RB.3 .C.2 II.C.3

Impact Non-native Non-native Non-native Non-native Non-native Non-native

Category Rats Control Rats Control Cats Control Cats Control Mongooses Mongooses
Control Control


Proposed Proposed Proposed
No Action Action No Action Action No Action Action


Highest potential
for adverse affects
from rats in the
Park on native
wildlife would
continue because
very large numbers
of native fauna
including several
native bird, reptile
and amphibian
species and
numerous insect
and spider species
are killed by
Norway and roof
rats.

Because herpto-
fauna and
invertebrates are
small, often slow
and readily
available, they are
particularly
susceptible to local
extinction from rat
depredation.


Lowest potential for
adverse native
wildlife impacts
because Norway
and roof rats
populations would
be greatly reduced.

Very large numbers
of native fauna,
including several
native bird, reptile
and amphibian
species and
numerous insect and
spider species
would benefit when
the Norway and
roof rat populations
are kept low.

In addition, five
native bat species,
the only indigenous
mammals on the
island, would
benefit from
reduced predation.

Many birds, three
bat and one reptile
species are Locally
Endangered by the
Government of the
U.S. Virgin Islands.


Wildlife
Impacts


Lowest potential
for adverse native
wildlife impacts
because cat
populations would
be greatly reduced.

Wildlife impacts
would be positively
mitigated by this
action because very
large numbers of
native fauna
including several
native birds, reptile
and amphibian
species and
numerous insect
and spider species
would benefit when


Highest potential
for adverse affects
from mongooses in
the Park on native
wildlife would
continue.

Native wildlife
would continue to
be adversely
impacted by this
action because
mongooses
depredate very
large numbers of
native fauna
including several
native birds, reptile
and amphibian
species and


Highest potential
for adverse affects
from cats in the
Park on native
wildlife would
continue.

Native wildlife
would continue to
be adversely
impacted because
cats depredate very
large numbers of
native fauna
including several
native birds, reptile
and amphibian
species and
numerous insect
and spider species.

Because herpto-
fauna and
invertebrates are
small, often slow
and readily
available, they are
particularly
susceptible to local
extinction from cat
depredation.

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.

The Park has listed
over 232 common
insect species,
including 13
species of
dragonflies and
damselflies and
over 1500 beetle
species.


In addition, five
native bat species,
the only indigenous
mammals on the
island, would
benefit from
reduced predation.

Because herpto-
fauna and
invertebrates are
small, often slow
and readily
available, they are
particularly
susceptible to local
extinction from cat
depredation.

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.


Because
herptofauna and
invertebrates are
small, often slow
and readily
available, they are
particularly
susceptible to local
extinction from
mongoose
depredation.

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.

The Park has listed
over 232 common
insect species,
including 13
species of
dragonflies and
damselflies and
over 1500 beetle
species.


Lowest potential
for adverse native
wildlife impacts
because mongoose
populations would
be greatly reduced.

Wildlife impacts
would be positively
mitigated by this
action because very
large numbers of
native fauna
including several
native bird species
would benefit when
mongoose
populations are
kept low.

Mongooses
depredate eggs,
chicks or adults
from shorebird,
waterfowl and
other birds nesting
on or near the
ground. Likewise,
numerous species
of reptiles would
benefit from
reduction of
mongoose
populations.


cat populations are numerous insect
kept low. and spider species.


SUSTAINED REDUCTION NON-NATIVE RATS, CATS & MONGOOSES ENVIRONMENTAL ASSESSMENT
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Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5 Alternative 6
I.A2 ILA3 IB.2 RB.3 IC.2 II.C.3
Impact Non-native Non-native Non-native Non-native Non-native Non-native
Category Rats Control Rats Control Cats Control Cats Control Mongooses Mongooses
Control Control

Proposed Proposed Proposed
No Action Action No Action Action No Action Action

Water No adverse Same as Same as Same as Same as Same as
y impacts would be Alternative 1. Alternative 1. Alternative 1. Alternative 1. Alternative 1.
Quality expected.
Impacts


Wetlands/ Highest potential Lowest potential for Highest potential Lowest potential Highest potential Lowest potential
for adverse affects adverse native for adverse affects for adverse native for adverse affects for adverse native
Floodplain from Norway and wildlife impacts from cats in the wildlife impacts from mongooses in wildlife impacts
Impacts roof rats in the because Norway Park on native because cat the Park on native because mongoose
Park on native and roof rats wildlife using populations would wildlife using populations would
wildlife using populations would wetlands and be greatly reduced wetlands and be greatly reduced
wetlands and be greatly reduced floodplains would in and adjacent to floodplains would in and adjacent to
floodplains would in and adjacent to continue. Park wetlands and continue. Park wetlands and
continue. Park wetlands and floodplains. floodplains.
floodplains. Adverse impacts to Adverse impacts to
Adverse impacts to wetlands, mainly Wetlands and wetlands, mainly Wetlands and
wetlands, mainly Wetlands and salt ponds, and floodplains impacts saltponds, would floodplains impacts
saltponds, would floodplains impacts would continue are positively continue under this are positively
continue under this are positively under this affected under this alternative as the affected under this
alternative as the affected under this alternative as the alternative, native flora and alternative.
native flora and alternative, native flora and fauna continue to
fauna continue to fauna continue to More native flora change under the More native flora
change under the More native flora change under the and fauna would foraging and and fauna would
foraging and and fauna would foraging and exist in and predation pressure exist in and
predation pressure exist in and adjacent predation pressure adjacent to these of mongooses adjacent to these
of rats throughout to these areas as of cats throughout areas as foraging throughout the areas as foraging
the Park. foraging and the Park. and predation Park. and predation
predation pressure pressure from cats pressure from
This is especially from rats decrease. This is especially decrease. This is especially mongooses
problematic where problematic where problematic where decrease.
salt ponds occur salt ponds occur salt ponds occur
near centers of near centers of near centers of
human activities, human activities, human activities,
e.g. Annaberg e.g. Annaberg e.g. Annaberg
Sugar Plantation, Sugar Plantation, Sugar Plantation,
Francis Bay, etc. Francis Bay, etc. Francis Bay, etc.


Park Highest potential Lowest potential for Highest potential Lowest potential Highest potential Lowest potential
for adverse diverse operational for adverse for adverse for adverse for adverse
Operations operational affects affects because operational affects operational affects operational affects operational affects
Impacts from Norway and Norway and roof rat from cats on the because cat from mongooses on because mongoose
roof rats on the populations would Park's populations would the Park's populations would
Park's be greatly reduced administrative, be greatly reduced administrative, be greatly reduced
administrative, throughout the Park resources throughout the Park resources throughout the Park
resources at all visitor use, management, at all visitor use, management, at all visitor use,
management, administrative, interpretation, law administrative, interpretation, law administrative,
interpretation, law cultural and natural enforcement and cultural and natural enforcement and cultural and natural
enforcement and resources sites. maintenance costs resources sites. maintenance costs resources sites.
maintenance costs would be expected would be expected
would be expected to continue, to continue.
to continue.



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Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5 Alternative 6
1L.A2 1LA3 II.C.2 LB.3 ILC.2 II.C.3

Impact Non-native Non-native Non-native Non-native Non-native Non-native

Category Rats Control Rats Control Cats Control Cats Control Mongooses Mongooses
Control Control


Proposed Proposed Proposed
No Action Action No Action Action No Action Action


Cumulative
Impacts


Highest potential
for adverse
cumulative affects
from non-native
Norway and roof
rats in the Park.

The cumulative
impacts from this
alternative would
have severe
negative
consequences for
National Park
Service lands and
wildlife. Every
native terrestrial
plant, animal and
invertebrate
species would be
adversely impacted
under this
alternative.

The greatest
impact would be
changes in plant
species
composition and
the associated
changes in native
fauna, including
birds, bats, tree
frogs and insect
species.

Eventually, many
species would
become locally
extinct, some
before they are
even identified by
scientists.


Lowest potential for
adverse cumulative
affects from non-
native Norway and
roof rats in the Park.

The cumulative
impacts from this
alternative would
have very positive
consequences for
National Park
Service lands,
wildlife and marine
waters.

Fewer rats would
disperse less disease
causing organisms
in tents, on picnic
tables, in restrooms
and bathing
facilities.

A small residual rat
population may
remain due to the
difficulties in
removing 100% of
the population;
however, NPS does
not intend to
maintain a residual
population.

Implementing this
reduction program
should result in rats
that avoid human
habitations in both
day and night time.


Highest potential
for adverse
cumulative affects
from non-native
cats in the Park.

The cumulative
impacts from this
alternative would
have severe
negative
consequences for
National Park
Service lands and
wildlife.

Every native
terrestrial plant,
animal and
invertebrate species
would be adversely
impacted under this
alternative. The
greatest impact
would be changes
in plant species
composition and
the associated
changes in native
fauna, including
birds, bats, tree
frogs and insect
species.

Eventually, many
species would
become locally
extinct, some
before they are
even identified by
researchers.


Lowest potential
for adverse
cumulative affects
from non-native
cats in the Park.

The cumulative
impacts from this
alternative would
have very positive
consequences for
National Park
Service lands
wildlife and marine
waters.

Fewer cats would
disperse less
disease causing
organisms in tents,
on picnic tables, in
restrooms and
bathing facilities.

A very small
residual cat
population may
remain due to the
difficulties in
removing 100% of
the population;
however, NPS does
not intend to
maintain a residual
population.

Implementing this
reduction program
should result in cats
that avoid human
habitations in both
day and night time.
New cats are
expected to
occasionally enter
centers of human
activity and these
would be promptly
trapped and
removed.


Highest potential
for adverse
cumulative affects
from non-native
mongooses in the
Park.

The cumulative
impacts from this
alternative would
have severe
negative
consequences for
National Park
Service lands and
wildlife.

Almost every
native terrestrial
plant, animal and
invertebrate species
would be adversely
impacted under this
alternative. The
greatest impact
would be changes
in wildlife species
composition and
the associated
changes in native
flora.

Eventually, many
species would
become locally
extinct, many
before they are
even identified by
scientists.


Lowest potential
for adverse
cumulative affects
from non-native
mongooses in the
Park.

The cumulative
impacts from this
alternative would
have very positive
consequences for
National Park
Service lands,
wildlife and marine
waters.

Fewer mongooses
would disperse less
disease causing
organisms in tents,
on picnic tables, in
restrooms and
bathing facilities.

A small residual
mongoose
population may
remain due to the
difficulties in
removing 100% of
the population;
however, NPS does
not intend to
maintain a residual
population.

Implementing this
reduction program
should result in
mongooses that
avoid human
habitations in both
day and night time.


SUSTAINED REDUCTION NON-NATIVE RATS, CATS & MONGOOSES ENVIRONMENTAL ASSESSMENT
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V. CHAPTER V. COMPLIANCE WITH

ENVIRONMENTAL LAWS AND REGULATIONS

The proposed program for a sustained reduction of non-native rat, non-native cat and non-native
mongoose populations from Virgin Islands National Park is consistent with the National Park Service
Organic Act (16 U.S.C.) "to conserve the scenery and the natural and historic objects and the wild life
therein and to provide for the same in such a manner and by such means as would leave them unimpared
for the enjoyment of future generations."

(a) Federal Insecticide, Fungicide and Rodenticide Act (FIFRA)(7 U.S.C. 136 et seq.) The
rodenticide proposed for use diaphacione (Eaton's Bait Blocks) is a general use product registered by the
Environmental Protection Agency for use in and around man-made structures. In order to use this
product in the natural area at Virgin Islands National Park, the NPS and Wildlife Services has obtained a
special Section (c) registration for the product through the Government of the Virgin Islands' Department
of Planning and Natural Resources Division of Environmental Protection. This permit is consistent with
the FIFRA. The Park has also obtained pesticide use approval through the Southeast Regional Integrated
Pest Management Program (IPM) and the Washington IPM Office.

(b) Endangered Species Act of 1973 (ESA)(7 U.S.C. 136, as amended) Virgin Islands National Park
provides habitat for Endangered Hawksbill and Leatherback sea turtles at numerous beach areas along the
north, east and southern beaches. Endangered Brown Pelicans nest extensively along a section of the
north shore area. Endangered Roseate and Threatened Least Terns nest at several sites in the Park. In
order to comply with the ESA of 1973, the Park must protect endangered species and their habitats (PL
93-205). NPS initiated consultation about this program with the U.S. Fish and Wildlife Service on April
16, 2001. A response letter from U.S. Fish and Wildlife Service on September 7, 2001 indicated that
there are no adverse effects on listed species from the proposed action, thereby concluding consultation
under Section 7 of the Endangered Species Act.

(c) Migratory Bird Treaty Act of 1918 (40 Stat 755) provided clear authority and direction for the
proposed action.

(d) Animal Damage Control Act of 1931 gives authority to remove injurious animals for the protection
of birds and other wildlife.

(e) Coastal Zone Management Act (16 U.S.C. 1 {1916} etseq.) "Preserve, protect, develop and where
possible restore or enhance the resources of the nation's coastal zones" supports the removal of non-
native pests that damage the coastal zone and wildlife therein. With release of Draft EA, NPS
initiated formal consultation with the Territory's Department of Planning and Natural Resources in
conformance with the Coastal Zone Management Act; this consultation is ongoing.

(f) General Management Plan Virgin Islands National Park, 1983 non-native and non-native
pests such as rats and mongooses, as well as non-native cats, are identified as a threat to native fauna
and flora and must be controlled.

(g) National Historic Preservation Act of 1966 (16 U.S.C. 470 et seq,), Archeological Resources
Protection Act of 1979 (16 U.S.C. 470aa-ll). With release of Draft EA, on June 18, 2001, NPS
initiated formal consultation with the State Historic Preservation Office regarding effects on the
Park's archeological and cultural resources. This office expressed no concerns about the proposed
program.
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SUSTAINED REDUCTION NON-NATIVE RATS, CATS & MONGOOSES ENVIRONMENTAL ASSESSMENT
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(h) National Environmental Policy Act of 1969 (NEPA) (42 U.S.C. 4332, as amended). Title I of
NEPA require that federal agencies plan and carry out their activities... "so as to protect and enhance
the quality of the environment. Such activities shall include those directed to controlling pollution
and enhancing the environment." With release of Final EA, NPS will complete the NEPA process.

(i) Resource Management Plan Virgin Islands National Park, 1999 feral and non-native pests,
such as non-native rats and mongooses, as well as non-native cats, are identified as a threat to native
fauna and flora and must be controlled.
















































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VI. CHAPTER VI. CONSULTATION AND

COORDINATION


Personnel from the following agencies and organizations have been consulted or participated in the
formulation of this Environmental Assessment:

U.S. Department of the Interior

National Park Service
Carol DiSalvo Washington Integrated Pest Management
National Park Service
P.O. Box 37127
Washington, DC 20013-7127

Chris Furqueron Southeast Region Integrated Pest Management
Southeast Regional Office
1924 Building, 100 Alabama St. SW
Atlanta, GA 30303

James Oland, Supervisor
Caribbean Field Office
U. S. Fish and Wildlife Service
P.O. Box 510
Boqueron, PR 00622

Zandy Hillis-Starr Resources Management Specialist Buck Island Reef NM
2100 Church Street, Kings Wharf #100
Christiansted, St. Croix, U.S. Virgin Islands 00820-4611

U.S. Department of Agriculture

Animal Plant Health Inspection Service / National Wildlife Research Center
Frank Boyd State Director/Coordinator
118 Extension Hall
Auburn University, Auburn, AL 36849-5656

Government of the Virgin Islands

Dr. David Nellis
DPNR Division of Fish and Wildlife
6291 Estate Nazareth 101
St. Thomas, U.S.V.I. 00802-1104







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SUSTAINED REDUCTION NON-NATIVE RATS, CATS & MONGOOSES ENVIRONMENTAL ASSESSMENT
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VII. CHAPTER VII. PLANNING TEAM /

PREPARERS

Ralf H. Boulon, Jr., Chief, Resource Management Division, Virgin Islands National Park
Thomas Kelley, Natural Resources Program Manager, Virgin Islands National Park
Jim Benedict, Natural Resources Program Manager, Virgin Islands National Park

USDA / APHIS / NWRC
Frank Boyd State Director/Coordinator
118 Extension Hall
Auburn University, Auburn, AL 36849-5656


John King, Superintendent, Virgin Islands National Park

Judy Shafer, Deputy Superintendent, Virgin Islands National Park
Jim Owens, Park Planner, Virgin Islands National Park
Bridgett Wanderer, Landscape Architect, Virgin Islands National Park
R.W. Jenkins, Facility Manager, Virgin Islands National Park
Schuler Brown, Chief Ranger, Virgin Islands National Park
Paul Thomas, Chief of Interpretation, Virgin Islands National Park
Elba Richardson, Concessions Manager, Virgin Islands National Park
Dottie Anderson, Chief of Administration, Virgin Islands National Park



























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SUSTAINED REDUCTION NON-NATIVE RATS, CATS & MONGOOSES ENVIRONMENTAL ASSESSMENT
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VIII. CHAPTER VIII. REFERENCES CITED

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Arnold, B. 1986. San Miguel Island rat trapping effort, August 1978-April 1979. U. S. Department of
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Baker, James K., and Christa A. Russell. 1979. Mongoose predation on a nesting Nene. 'Elepaio
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Boulon, RalfH. 1999. Reducing threats to eggs and hatchlings: In situ protection. Research and
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Childs, J. E. 1991. And the cat shall lie down with the rat. Natural History: pages 16-19.

Coblentz, Bruce E. 1983. Exotic animal influences in Virgin Islands National Park. Report to NPS, St.
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Coleman, J. S., and S. A. Temple. 1995. How many birds to cats kill? Wildlife Control Technology:44.

Conry, Paul J. 1994. Narrative in Support of an Application for an SLN 24C Special Local Need
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Curry, C. 1970. Entomological checklist for the Virgin Islands Ecological Research Station and Virgin
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Donald, R. L. 1992. Should feral cats be euthanized? Shelter Sense. Pages 3-7.



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SUSTAINED REDUCTION NON-NATIVE RATS, CATS & MONGOOSES ENVIRONMENTAL ASSESSMENT
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National Park Service. 1989. Natural Resources Management Guideline (NPS-77). U. S. Department of
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SUSTAINED REDUCTION NON-NATIVE RATS, CATS & MONGOOSES ENVIRONMENTAL ASSESSMENT
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National Park Service. 1997. Collections Management Plan, Virgin Islands National Park. Cruz Bay, St.
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Nellis, David W. and C.O.R. Everard. 1983. The biology of the mongoose in the Caribbean. Studies on
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Passanisi, W. C., and D. W. Macdonald. 1990. The fate of controlled feral cat colonies. Universities
Federation for Animal Welfare, Hertfordshire, England. 48 pages.

Ray, G. 1990. Feral donkey impacts to native forests. Letter to NPS Resources Management Specialist.
Cruz Bay, St. John, U.S. Virgin Islands.

Robertson, H. A, R. M. Colboume, P. J. Graham, P. J. Miller and R. J. Pierce. 1999. Survival of brown
kiwi (Apteryx mantelli) exposed to brodifacoum poison in northland, New Zealand. New Zealand Journal
of Ecology 23(2):225-231.

Rogers, Caroline. 1988. Recommendations for Long-term Assessment of Coral Reefs: U.S. National
Park Service initiates national program. NPS Report. Cruz Bay, St. John, U.S. Virgin Islands. 11 pages.

78
SUSTAINED REDUCTION NON-NATIVE RATS, CATS & MONGOOSES ENVIRONMENTAL ASSESSMENT
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Sealy, D. 1996. Removal of a colony of free-ranging cats from an area administered by the National
Park Service: A case history, in. Proceedings of the 1995 International Wildlife Rehabilitation Council
Conference, Virginia Beach, VA. Pages 75-77.

Seaman, George A., John E. Randall. 1962. The mongoose as a predator in the Virgin Islands. Journal of
Mammalogy 43(4):544-546.

Soule, M. E. 1990. The onslaught of alien species and other challenges in the coming decades.
Conservation Biology 4:233-239.

Stone, Charles P., Howard M. Hoshide, and Paul Christian Banko. 1983. Productivity, mortality and
movements of Nene in the Ka'u Desert, Hawaii Volcanoes National Park, 1981-1982. Pacific Science
38(3):301-311.

Stone, Charles P., Marsha Dusek, and Mark Aeder. 1995. Use of an anticoagulant to control mongooses
in Nene breeding habitat. 'Elepaio 54(12): 1-6.

Stone, Charles P., and Lloyd L. Loope. 1996. Alien species in Hawaiian national parks. Science and
Ecosystem Management in the National Parks. William L. Halvorson and Gary E. Davis (editors).
The University of Arizona Press, Tucson. Pages 132-158.

The Wildlife Society. 2001. Position statement: feral and free-ranging domestic cats. The Wildlifer. No.
306, page 57.

The Wildlife Society. 2001. "Managed" cat colonies in parks harmful to birds and other wildlife, new
study shows. The Wildlifer. No. 307, page 75.

Timm, Robert M, and Gerald R. Bodman. 1984. Rodent-proof construction. Prevention and Control of
Wildlife Damage. Cooperative Extension Service, Institute of Agriculture and Natural Resources,
University of Nebraska-Lincoln. Pages B-125 to B-132.

Treshy, B.R., and D.A. Croll. 1994. Avoiding the problems of fragmentation by conserving natural
fragments: the benefits of restoring and protecting small islands. In: Abstracts, Society for Conservation
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U. S. Environmental Protection Agency. 1988. The Federal Insecticide, Fungicide and Rodenticide Act,
As Amended. Washington, D. C. 73 pages.

Wilcove, D. S. 1985. Nest predation in forest tracts and the decline of migratory songbirds. Ecology
66:1211-1214.

Winter, Linda. 2000. Myths and facts about "managed" cat colonies. Cats Indoors! The Campaign for
Safer Birds and Cats. American Bird Conservancy. Washington, D.C. 2 pages.

Witmer, G, E. Campbell III, and F. Boyd. 1998. Rat Management for Endangered Species Protection in
the U.S. Virgin Islands, St. Croix Buck Island Trip Report, February 15-21, 1998. 20 pages.

World Conservation Monitoring Centre. 1992. Global Biodiversity: Status of the Earth's Living
Resources. Chapman and Hall, London.


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IX. CHAPTER IX. APPENDICES



















































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APPENDIX A. List of Endangered Plants and Animals of the U. S. Virgin
Islands
Compiled by the Division of Fish and Wildlife (DPNR), the UVI Cooperative Extension Service,
Eleanor Gibney (Caneel Bay), Gary Ray (U. of Wisconsin) and William Mclean (UVI).


Scientific Name


PLANTS


Common Name


Distribution/Remarks


Federal List
Buxaceae
Buxus vahlii
Rutaceae
Zanthoxyllum thomasianum
Myrtaceae
Calyptranthes thomasiana



Virgin Islands List
Agavaceae
Agave eggersiana
Aizoaceae
Cypselia humifusa
Aquifoliaceae
Ibex urbanii
I. sideroxyloides
Bromeliaceae
Tillandsia lineatispica
Cactaceae
Mammilaria nivosa
Opuntia triacantha
Celastraceae
Maytenus cymosa
Convolvulaceae
Operculina triquetra
Euphorbiaceae
Croton fishlocklii
Fabaceae
Erythrina eggersii
Galactia eggersii
Malpighiaceae
Malpighia woodburyana
M. infestissima (=pallens)
M.. linearis
Malpighia sp.
Byrsonima sp.
Malvaceae
Psidium amplexicaule
Psidium sp.
Sida eggersii
Myrtaceae
Eugenia sp.


Vahi's Boxwood

Prickly Ash

St. Thomas Lidflower


Egger's Agave



Urban's Holly
Central Amer. Oak


Pinon


Wooly Nipple


Egger's Cockspur
Egger's Galactia

Cowage Cherry
Stinging Bush


Endangered, St.X..- May be
extinct

Endangered, St T., St .J.

Endangered, St. T., St. J.


St.T., St.J.


St.J., Tortola
St.J.


Rare bromeliad, St.J., St. T.

St.X., St.J., St.T., offshore cays


Buck Is. (St.X.) St.T.,

St.X., St.T.

St.X., St.T. endemic

Recent St. J. sightings


St.T., St.J., St.X
St.T., St.J.

St.T., St.J., offshore cays
St.X.
All VI
Similar to M. coccigera, St. J.
New Species, St. J.

St. J.
St. J., new species?
N. offshore cays


Recent St. J. sightings


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Endangered Plants and Animals of the U. S. Virgin Islands (Cont.)


Olacaceae
Schoepfia schreberi
Orchidaceae
Brassavola cuccullata
Psychilis macconelliae
Encydia ciliare
E. cochleata
Habenana alata
Tolumnia (Oncidium) prionochila
T. variegatuni
Polystachya concrete
Ponthieva racemosa
Prescottia oligantha
P. stachyoides
Spiranthes torta
Tetrainicra canaliculata
T. canaliculata alba
Vanilla barbellata
Piperaceae
Peperomia myrtifolia
Polygonaceae
Coccoloba rugosa
Rubiaceae
Catesbaea melanocarpa
Machaonia woodburyana
Sapotaceae
Mani lkara bidentata
Solanaceae
Solanum mucronatuni
S. conocarpum
Urticaceae
Pilea richardii
Verbenaceae
Callicarpa ampla
Nashia inaguensis
Zygophyllaceae
Gualacum officinale


St.T., St.J., St.X.


Sandy Pt. Orchid
Christmas Orchid
Cockle-shell Orchid

Yellow Dancing Lady
White Dancing Lady








Vanilla Orchid

Myrtle-leaved Peperomia







Bulletwood





Richard's Clearweed

Capa Rosa

Lignum Vitae


St.T.
St.X.
St.T., St.J., St.X.
St.X.
St.T.
St. J, St.T.
St.T., St.J., St. X.
St.T., Virgin Gorda
St.T., St.J., Tortola
St.T., St.J., Tortola.
St.J.
St.T.
St.T., St.J., St. X.
End. subsp., Water Is.
St. T.

St.J., St.X


May be extinct in VI

St.X.
New St. J. sightings

St.T., St.J.

Confused taxonomy, St. T., St.J.
Rediscovered 1993, 2 indivs., St.J.

St.T.

Info. needs update
St.X.

W..I., High hort. demand


ANIMALS


Federal List
Chelonia mydas
Eretmochelys imbricata
Dermochelys coriacea
Pelecanus occidentalis
Falco peregrinus
Epicrates monensis granti
Ameiva polops
Sterna dougallii


Green turtle
Hawksbill turtle
Leatherback turtle
Brown pelican
Peregrine falcon
VI Tree boa
St. X. ground lizard
Roseate tern


Threatened, Resident, breeding
Endangered, Resident, breeding
Endangered, Migrant, breeding
Endangered, Resident, breeding
Endangered, Winter migrant
Endangered, Resident, breeding
Endangered, Resident, breeding
Threatened, migrant, breeding


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Endangered Plants and Animals of the U.S. Virgin Islands (Cont.)


Virgin Islands List
Mabuya inabouia
Otus nudipes newtom
Chordeiles gundlachii
Anthracothorax dominicus
Podiceps dominicus
Sterna antillarum
Phaethon lepturus
Ardea herodius
Casmerodius albus
Egretta thula
Nycticorax nycticorax
Ixobrychus exilis
Anas bahaniensis
Oxyura j amaicensis
Rallus longirostris
Fulica caribea
Charadrius alexandrinus
Catoptrophorus semipalmatus
Puffinus Iherminieri
Aratinga pertinax
Columba leucocephala
Geotrygon mystacea
Myiarchus stolidus
Noctilio leporinus
Stenoderma rufum
Brachyphylla cavernarum
Order Antipatharia
Epinephelus itajara


Slipperyback skink
VI Screech owl
West Indian nighthawk
Antillean mango
Least grebe
Least tern
White-tailed tropicbird
Gt. blue heron
Great (common) egret
Snowy egret
Black-cr. night heron
Least bittern
Bahama duck
Ruddy duck
Clapper rail
Caribbean coot
Snowy plover
Willet
Audubon shearwater
Brown-throated parakeet
White-crowned pigeon
Bridled Quail dove
Stolid flycatcher
Fisherman bat
Red fruit bat
Cave bat
Black coral
Jewflsh


Resident, breeding
Resident, breeding?
Resident, breeding?
Resident, breeding?
Migrant, breeding
Resident, breeding
Resident, breeding
Resident, breeding
Resident, breeding
Resident, breeding
Resident, breeding?
Resident, breeding
Peripheral resident
Resident, breeding
Resident, breeding
Resident, breeding?
Resident, breeding
Migrant, breeding
Resident, breeding
Resident, breeding
Resident, breeding
Resident, breeding
Resident, breeding
Resident, breeding
Resident, breeding
Marine benthic, high demand
Resident, breeding
Marine


The above list represents plants and animals occurring in the US Virgin Islands
which are protected by either the US Endangered Species Act of 1973 or the VI
Endangered and Indigenous Species Act of 1990 (Act No. 5665). This list is
promulgated under Act 5665, Section 104(g) and may be revised as new information
becomes available.




Roy E. Adams, Commissioner, DPNR
5 June 1991






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APPENDIX



Common Name

MAMMALS

Cat, domestic

Cattle, domestic

Deer, White-tail

Dog, domestic

Donkey

Goat, domestic

Horse

Pig, domestic

Mongoose, Indian

Mouse, house

Rat, black

Rat Norway

Sheep, domestic

BIRDS

Bullfinch, L.Ant.

Fowl, domestic

Parakeet, Bm-thr

Sparrow, English

AMPHIBIANS

Tree frog, Cuban

Tree Frog, Coqui

REPTILES

Iguana, green

Tortoise, redfoot


B. List of Introduced Animals to St. John, U. S. Virgin Islands


Area of When Introduced
Scientific Name Origin Introduced By


Felis catus

Bos taurus

Odocoileus virginianus

Canis familiaris

Equus asinus

Capra hircus

Equus caballus

Sus scrofa

Herpestes auropunctatus

Mus musculus

Rattus rattus

Rattus norvegicus

Ovis aries




Loxigilla noctis

Various sp.

Aratinga pertinax

Passer domesticus




Osteopilus septentrionalis

Eleutherodactylus Coqui



Iguana iguana

Geochelone carbonaria


Afr./SW Asia

Eurasia

U.S.

Eurasia

N. Africa

SW Asia

Eurasia

Eurasia

India

Mid E/Asia

SE Asia

SE Asia

Mid East




Lesser Ant.



Curacao

Eurasia




Cuba

Puerto Rico



S. America

S. America


1700's






1500's



1500's

1880's













1960's



1900's

1980's




1980's

1970's



<1500':

<1500':


9


Europeans

Europeans

Europeans

Europeans

Europeans

Spaniards

Europeans

Spaniards

Europeans

Europeans

Europeans

Europeans

Europeans


Natural

? Various

Unknown

Ship



Plant trade

Residents



s Native Ams.

s Native Ams.


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APPENDIX C. Sample Eaton Bait Blocks Rodenticide 24c Label
FOR DISTRIBUTION AND USE ONLY WITHIN THE UNITED STATES VIRGIN ISLANDS
JT EATON

BAIT BLOCKS
RODENTICIDE WITH FISH FLAVORIZER-
FOR CONTROL OF RODENTS AND MONGOOSE FOR CONSERVATION PURPOSES
For use by or in cooperation with federal government conservation agencies only.

ACTIVE INGREDIENTS:
Diphacinone (2 diphenylacetyl-L, EPA SLN NO.
3-Indandione): 0.005%
Total 100.00% OTHER INGREDIENTS: 99.995 %
NOTICE Buyer assumes all risks ofuse, storage or CAUTIO N handling ofthis material not in strict accordance with

directions given herewith. The efficacy of Notice: Buyer assumes all risks of use, storage or handling of this material not in strict accordance with

PRECAUTIONARY STATEMENTS
HAZARD TO HUMANS AND DOMESTIC ANIMALS
CAUTiON Keep away from humans, domestic animals and pets, If swallowed, this material may reduce the clotting abilityofthebbod
and cause bleeding. NOTE TO PHYSICIAN If Ingested administer Vitamin KI intramuscularly or orally, as indicated In
bishydroxycoumarin overdoses. Repeat as necessary based on monitoring of prothrombln times. ENVIRONMENTAL HAZARD
This product Is to3dc to mammals and birds. Do not apply this product directly to water or to areas where surface water is present
or to Intertidal area & below the mean high water mark.

STORAGE AND DISPOSAL
DO NOT CONTAMINATE WATER. FOOD, OR FEED BY STORAGE OR DISPOSAL STORAGE: Store only in original container, In a
cool, dry place inaccessible to children and pets. PESTICIDE DISPOSAL Wastes resulting from use of this product may be disposed
of on site or at an approved waste disposal facility. On site disposal shall be at a depth such that it will not result hi exposure to
non-target animals. CONTAINER DISPOSAL When container is empty, dispose of it In a sanitary landfill or by Incineration, or, If
allowed by state and local authorities, by burning. If burned, stay out of smoke.
directions given herewith. The efficacy of the product may be reduced under high moisture conditions.


NET WT. 50 LBS.
DIRECTIONS FOR USE
It is a violation of Federal law to use this product in a manner inconsistent with its labeling. Persons using this product shall complywihl all applicable
directions, restrictions and precautions found on this labeling. This label most be in the possession of the user at the time of pesticide application.
READ THIS LABEL Read this entire label and follow all use directions and use precautions.
IMPORTANT:Do not expose children, pets, or other nontarget animals to rodenticides. To help prevent accidents:
I. Store product no in use in a location out of reach of children and pets.
2. Apply bait in locations out of reach of children, pets, domestic animals and nontarget wildlife, or in tamper.-resistantbait stations. These stationsmost
be resistant to destruction by dogs and by children under six years of age, and most be used in a mower that prevents such chldenfrom reaching into bait
compartments and obtaining bait. If bait can be shaken from stations when they are lifted, units must be secured or otherwise immobilized. Even stronger
bait stations are needed in areas open to hoofed livestock or other potentially destructive animals, or in areas prone to vandalism.
3. Dispose of product container, and unused, spoiled, and unconsumed bait as specified on this label.
USE RESTRICTIONS: For the control of Small Indian Mongoose (Herestes auropunctatus), Roof rats (Rathis rattus), Norway rats (Rniaveticus),and
House nice (Mus musculus) in forests, offshore islands and other non-crop outdoor areas to protect native and endangered plants and animals.
Do not apply bait in or around food crops. Do not apply bait within 15 feet of any open body ofwaterorinamannerinwhichbaitmaycontaminatewater
sources. Report signs of secondary poisoning to animals other than rodents and mongoose to the Pesticides Branch of the Virgin Islands Department of
Planning and Natural Resources.
BAITING: Bait stations may be located on the ground or in trees. Place bait stations over the area in which rodent and mongoose control is desired. Space
stations 75- to 330-foot intervals to ensure that all rodents and mongoose will be exposed to bait. Apply 2 to 8 baitblocks(4to 16 ounces) per station..
Maintain an uninterrupted supply of fresh bait for at least 10 days or until feeding has stopped. Replace contaminated or spoiled bait immediately. Where
a continuous.sourcc of infestation is present, permanent bait stations may be established and bait replenished as needed.
Check area periodically and collect and dispose of any dead animals found. Spoiled or uneaten bait and dead animals collected may be buried on-site or
taken to a sanitary landfill for disposal. Burial on site shall be at a depth such that it will not result in exposure to non-target animals.
Bait stations must have the name and phone number of the responsible agency. Treated areas shall be posted with warning signs.

Manufactured by
J.T. EATON & COMPANY, INC.
1393 East Highland Road, Twinsburg, OH 44087 USA
JT EATON' and BAIT BLOCKER' are registered trademarks and
FLAVORIZER" is a trademark of .J. T. EATON & CO., INC.
"This label is valid until January 1.2003 or until otherwise amended, canceled or
suspended."


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APPENDIX D. The Wildlife Society Position Statement Concerning Feral
Domestic Cats

No. 306 The Wildlifer

FERAL AND FREE-RANGING DOMESTIC CATS

SPosition Statement

<2 Free and free-ranging domestic cats are exotic species to North America.
S\ Exotic species are recognized as one of the most widespread and serious threats
S, to the integrity of native wildlife populations and natural ecosystems. Exotic
species present special challenges for wildlife managers because their negative
Impacts are poorly understood by the general public, many exotic species have
become such an accepted component of the environment that many people
regard them as "natural," some exotic species have advocacy groups that
promote their continued presence, and few policies and laws deal directly with
their control. Perhaps no issue has captured more of the challenges for contemporary wildlife management than the
impacts of feral or free-ranging human companion or domestic animals. The domestic cat is the companion animal that
recently has attracted the most attention for its impact on wildlife species.

Domestic cats originated from an ancestral wild species, the European and African wild cat (Fells silvestris). The domestic
cat (Fells catus) is now considered a separate species. The estimated numbers of pet cats in urban and rural regions of the
United States have grown from 30 million in 1970 to nearly 65 million in 2000. Reliable estimates of the present total cat
population are not available. Nationwide, approximately 30% of households have cats. In rural areas, approximately 60%
of households have cats.

The impact of domestic cats on wildlife is difficult to quantify. However, a growing body of literature strongly suggests
that domestic cats are a significant factor in the mortality of small mammals, birds, reptiles, and amphibians. Because free-
ranging cats often receive food from humans, they can reach population levels that may create areas of abnormally high
predation rates on wildlife. When the wildlife prey is a threatened or endangered species, the result may be extirpation or
extinction. Effects of cat predation are most pronounced in island settings (both actual islands and island of habitat), where
prey populations are already low or stressed by other factors, or in natural areas where cat colonies are established.
Competition with native predators, disease implications for wildlife populations, and pet owners' attitudes toward wildlife
and wildlife management also are important issues.

Extensive popular debate over absolute numbers or types of prey taken is not productive. The number of cats is undeniably
large. Even if conservative estimates of prey taken are considered, the number of prey animals killed is immense. Feeding
cats does not deter them from kiffing wildlife as they do not always eat what they kill. Humans introduced cats to North
America and they must be responsible for the control and removal of cats that prey on wildlife.

The policy of The Wildlife Society in regard to feral and free-ranging domestic cats is to:

I. Strongly support and encourage the humane elimination of feral cat colonies.
2. Support the passage and enforcement of local and state ordinances prohibiting the public feeding of feral cats,
especially on public lands, and releasing of unwanted pet or feral cats into the wild.
3. Strongly support educational programs and materials that call for all pet cars to be kept indoors, in outdoor enclosures
or on a leash.
4. Support programs to educate and encourage pet owners to neuter or spay their cats, and encourage all pet adoption
programs to require potential owners to spay or neuter their pet.
5. Support the development and dissemination of sound, helpful information on what individual cat owners can do to
minimize predation by free-ranging cats.
6. Pledge to work with the conservation and animal welfare communities to educate the public about the negative impact
of free-ranging and feral cats on native wildlife, including birds, small mammals,
reptiles, amphibians, and endangered species.
7. Support educational efforts to encourage the agricultural community to keep farm cat
numbers at low, manageable levels and use alternative, environmentally safe rodent con-
trol methods.
8. Encourage researchers .to develop better information on the impacts of feral and free-
ranging cats on native wildlife populations.
9. Recognize that cats as pets have a long association with humans, and that responsible cat
owners are to be encouraged to continue caring for the animals under their control.
10. Oppose the passage of any local or state ordinances that legalize the maintenance of
"managed" (trap/neuter/release) free-ranging cat colonies.
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APPENDIX E. Consultation Letter from U. S. Fish and Wildlife Service



SUnited States Department of the Interior
FISH AND WILDUFE SERVICE
Boqueron Field Office
P.O. Box 491
Boqueron, Puerto Rico 00622 o 3fl

Received
September 7, 2001 SEP 1 3, 2001
Mr. John H. King, Superintendent
U.S. Department of the Interior Superintendent's Office
National Park Service VIIS National Park
Virgin Island National Park
P.O. Box 710, Cruz Bay
St. John, Virgin Islands 00831

Re: Draft Environmental Assessment for
Sustained Reduction of Rats, Cats, and
Mongooses from the Virgin Island National
Park

Dear Mr. King:

Thank you for the opportunity to review the draft Environmental Assessment for the Sustained
Reduction of Cats, Rats, and Mongoose for the Virgin Island National Park. The project will be
conducted through an Interagency Agreement with the U.S. Department of Agriculture. A number
of federally-listed threatened and endangered species occur within the Virgin National Park,
including the hawksbill sea turtle (Eretmochelys imbricata), the green sea turtle (Chelonia
mydas), the leatherback sea turtle (Dermochelys coriacea), the Brown Pelican (Pelecanus o.
occidentalis), Cal) lu ,illunh' thomasiana, and Zanthoxylum thomasianum.

Based on our review of the document we believe that these species are not likely to be adversely
affected by the proposed action. Indeed, the reduction in such species may benefit these as well as
species of concern and species protected by the U.S. Virgin Islands. If the project is modified or if
information on impacts to listed species becomes available this office should be contacted
concerning the need for additional consultation. if we may be of further assistance, please contact
me at 787/851-7297, ext. 30.

Sincerely,

Susan R. Silander
Acting Field Supervisor






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