Violation and Assessment Reports from Previous Projects managed by contractor Island Conservation.
Notice to USFWS of Violations Committed in Aerial Drop of Rodenticide on Rat Island, issued by the State of Alaska's Department of Environmental Conservation [PDF]
Violations included applying pesticides in a manner that resulted in significant non-target mortality of gulls, bald eagles and other non-target prey and exceeding the allowable application rates as set forth on the pesticide label.
Report describes high mortality of birds (400 count). Page 14 of the report shows that requirements allowing "takes" (collateral kills) of birds under the Migratory Bird Treaty Act may have been purposely avoided.
Citing irregularities in bait application, inadequate documentation of the basis of decisions, applications did not follow the operational plan.
Correspondence re: a 942-day recommended ban on consumption of fish, following an aerial drop of brodifacoum rodenticide at Wake Island. [PDF}