May 22, 2023

Environmental, Natural Resources, & Energy Law Blog

“Navy & Fish and Wildlife Service – Go Team!” - John Scott Cramer


John Scott Cramer LLM

Emerging Topics


Table of Contents



San Clemente Island and Navy Training………………………………….………3

Navy Recovery Actions ………………………………………………………..….….5

San Clemente Island’s Naval Future………………………………………….……8

Delisting and Compliance Programs……………………………………………….8






This paper discusses the US Navy’s combat training at San Clemente Island off the coast of Southern California and how the intense military training drills on the Island impact protected species there. The paper starts with background and then discusses Naval initiatives regarding protected species. Finally, the paper evaluates how the Navy’s initiatives in concert with the U.S. Fish and Wildlife Service (hereafter “FWS”) led to a successful delisting of endangered and threatened species on the Island.

San Clemente Island is host to several species of plants and animals protected under the Endangered Species Act (hereafter “ESA”).Due to the successful protective measures of the Navy on the Island, the FWS has removed the San Clemente Island Bell’s Sparrow (Artemisiospiza belli clementeae) (formerly known as the San Clemente Island Sage Sparrow, Amphispiza belli clementeae), San Clemente Island Bush-Mallow (Malacothamnus clementinus), San Clemente Island Paintbrush (Castilleja grisea), San Clemente Island Lotus (Acmispon dendroideus var. traskiae), and San Clemente Island Larkspur (Delphinium variegatum ssp. kinkiense) from the Federal Lists of Endangered and Threatened Wildlife and Plants lists. [See Ref 2,4.] The bird species and the four plant species occur only on San Clemente Island. The delistings are based on evaluation of the best available scientific and commercial information, which indicates that the status of each species has improved and threats to the species have been eliminated or reduced to the point that the species have recovered and no longer meet the definitions of either endangered or threatened species under the Endangered Species Act of 1973. [See Ref 2.] Accordingly, the protections provided by the ESA will no longer apply to these species. The Botany Manager aboard the Naval Base Coronado, stated that San Clemente Island has “17 plant species found here that are found nowhere else in the world.” [See Ref 4.]


The Navy is required to conduct rigorous, dangerous, and extensive combat training on San Clemente Island in preparation for future combat. As the Navy continues to conduct extensive military training on the Island, the delisting of five species from the endangered species list is a major accomplishment of the Navy and the Fish and Wildlife Service. This paper is an assessment of the adequacy of the protected species programs, and the issues of military training on San Clemente Island that will possibly impede or reverse advances in the recovery of these five species.

San Clemente Island and Navy Training

San Clemente Island is owned by the Navy and serves as the primary maritime training area for the Pacific Fleet and Sea Air and Land Teams. The Island also supports training by the Marine Corps, the Air Force, the Army, and other military organizations. As the Westernmost training range in the eastern Pacific Basin, where training operations are performed prior to troop deployments, portions of the island receive intensive use by the military. (See Ref 2.).

Infrastructure, including runways, buildings, fuel distribution network, training facilities, berthing areas, and associated development, is concentrated at the northern half of the Island. The remainder of the Island supports scattered operations buildings, training facilities, an electrical distribution system, and Ridge Road running along the central plateau of the Island. In addition to existing infrastructure, military exercises and training activities occur within designated training areas on the Island and have the potential to affect the SCI species. Altogether, 34.8 percent of the Island’s area is currently in one of these training areas, although training does not occur uniformly within each area. Military training activities can involve the movement of assault vehicles and troops over the landscape and can include live munitions fire, incendiary devices, demolitions, and bombardment.[See Ref 3.]

The Shore Bombardment Area (SHOBA) occupies roughly the southern third of the Island and encompasses approximately 13,824 acres. Areas of intensive use within SHOBA include two Impact Areas and three Training Areas and Ranges. Impact areas support naval gun firing, artillery firing, and air-to-ground bombing. Much of the remainder of SHOBA serves as a buffer around Impact Areas; thus, 59 percent of SHOBA is not within intensive training areas subject to direct training activities.[See Ref 2.] Some areas, particularly the escarpment along the eastern coast, have limited training value because precipitous terrain hinders ground access.[See Ref 3.]

These extensive military training activities can threaten the listed endangered or threatened species on the Island. Training and other land use activities have multiple potential impacts, including trampling or crushing individuals or groups of plants; disturbance of nesting birds or injury or mortality of nestlings; and habitat impacts including disturbances to soil and vegetation, spread of non-native plant species, creation of road ruts and trails, compaction of soils, and fires. [See Ref 3.]

Navy Recovery Actions

To mitigate the impacts of its training practices on the Island species and in aid of their recovery overall, the Navy has taken a variety of recovery actions in concert with FWS [See Ref 2.]. These include:

  • Removing all feral herbivores, which was achieved in 1992.
  • Monitoring and control of the expansion of highly invasive, non-native plant species on an ongoing basis since the 1990’s.
  • Implementing a non-native wildlife program initiated by the Navy.
  • Conducting and funding surveys, research, monitoring to better understand the ecology and habitat requirements of sensitive species, and monitoring their status and the effectiveness of recovery efforts.
  • Conducting long-term vegetation monitoring studies.
  • Conducting propagation and out planting (transplant plants from the greenhouse to vegetative communities) of non-listed native species through a contract with the San Diego State University Soil Ecology and Restoration Group. Although the restoration efforts were not specifically designed for the benefit of the species addressed in this final rule, restoration of the Island’s vegetation communities has helped to improve habitat suitability for the subject species by reducing the spread of invasive, non-native plants and restoring ecological processes.
  • Conducting annual reviews of fire management and fire occurrences, allowing for adaptive management to minimize the frequency and spread of fires. For example, in 2017, after a large fire that burned part of the eastern escarpment had seemingly gone out, the fire restarted the next day and response was therefore delayed. This occurrence prompted a change in how the Navy monitors fires that are thought to be extinguished.
  • Addressing assault vehicle-related erosion through development of an erosion control plan for the vehicles. The Navy also incorporates erosion control measures into all site feasibility studies to minimize impacts from erosion and avoid impacts to listed species.

San Clemente Island’s Naval Future Use

In addition to the actions above, the Navy is currently drafting an environmental assessment to evaluate future training areas, exercises, and frequency on the Island. The Navy plans to increase its training frequency and intensity in existing training areas and to add new training areas. Up to 19 new helicopter Landing Zones may be designated. While these additional training areas are anticipated to have some environmental impacts, the Navy’s planned conservation measures in concert with the FWS’s guidance help ensure the viability of the five San Clemente threatened species.[See Ref 2.]

Post-Delisting and Compliance Programs

The conservation program manager for the Pacific Fleet stated that the general public would be surprised that “an Island that hosts this level of training is also recovering not just listed species, but ecosystem-wide recovery.” Pursuant to the Sikes Act, the Navy manages land and water resources on the Island with the goal to maintain long-term ecosystem health and minimize impacts to natural resources consistent with the operational requirements of the Navy’s training and testing mission. [See Ref 3.] Key components of the management are to: (1) facilitate sustainable military readiness and foreclose options for future requirements of the Pacific Fleet (2) protect, maintain, and restore priority native species to reach self-sustaining levels through improved conditions of terrestrial, coastal, and nearshore ecosystems; (3) promote ecosystem sustainability against testing and training impacts; and (4) maintain the full suite of native species, emphasizing endemic species. [See Ref 2.]

Currently, due to the mitigation measures undertaken by the Navy noted above, all five threatened species on the Island are now more widely distributed on the Island with a greater estimated number of individuals than were previously known. The FWS has removed the species from the ESA list.[See Ref 2.]

If at any time during the monitoring period data indicate that protective status under the ESA should be reinstated, the FWS can initiate listing procedures, including, if appropriate, emergency listing. At the conclusion of the monitoring period, review all available information to determine if relisting, the continuation of monitoring, or the termination of monitoring is appropriate.

The FWS will continue to coordinate with the Navy to implement effective post-delisting monitoring (PDM) for the San Clemente Island Bell’s Sparrow, San Clemente Island Lotus, San Clemente Island Paintbrush, San Clemente Island Larkspur, and San Clemente Island Bush-Mallow. [See Ref 2.] The PDM plan builds upon current monitoring techniques and research, as well as emerging technology and techniques. Monitoring will assess the species’ numbers, distribution, and threats status, as well as ongoing management and conservation efforts that have improved the status of the species since listing. The PDM plan identifies, to the extent practicable and in accordance with the current understanding of the species’ life history, measurable thresholds and responses for detecting and reacting to significant changes in the species’ populations, distribution, and viability. If declines are detected equaling or exceeding these thresholds, the FWS, in combination with the Navy, will investigate causes of these declines, including considerations of habitat changes, anthropogenic impacts, or any other significant evidence. The result of the investigation will be to determine if any of the species warrant expanded monitoring, additional research, additional habitat protection, or resumption of Federal protection. [See Ref 2.]

The FWS has stated, given the Navy’s past and current stewardship efforts, management for the species has been effective to date, and it is reasonable to expect that management will continue to be effective for the species and their habitats beyond a post-delisting monitoring period, and well into the future. The FWS also notes that it plans to work with the Navy to ensure post-delisting monitoring is conducted and to ensure future management strategies are implemented (as warranted) to benefit these species.[See Ref 3.]


While ongoing military training activities have the potential to impact all five San Clemente Island species, the majority of locations and habitats currently occur outside intensive training areas. Within training areas that overlap with the species’ distributions, many effects are expected to be infrequent, minor, or temporary. Additionally, the Navy is committed to protecting and managing natural resources on the Island. The Navy is committed to revising these measures as needed to address future impacts. As a wildlife biologist in charge of terrestrial wildlife and seabirds for the Naval Base Coronado stated, “The Navy holds these in public trust, and therefore, it takes care of them. So, when it comes off the Endangered Species List, that’s a signal that all of the work we have done is coming to fruition.”[See Ref 4.]

Training is expected to continue within the revised training footprint used for this analysis, and the intensity of training could increase in the future. With implementation of post-delisting monitoring, it is highly unlikely that future changes in military training on San Clemente Island will impede or reverse advances in the recovery of these five species.

Finally, as the Field Supervisor, Carlsbad Fish and Wildlife Office, states, It’s through partnerships like the one we have with the U.S. Navy, that enable us to meet our conservation mission. The Navy’s dedication over several decades was instrumental in the recovery of the San Clemente Island species.” [See Ref 3.]


(1)   Endangered Species Act of 1973 (ESA). The Endangered Species Act of 1973 (ESA) is a comprehensive Federal Act aimed to protect endangered species and their habitats.

(2)   The Rule by the Fish and Wildlife Service of 01/25/2023. “End Endangered and Threatened Wildlife and Plants; Removing Five Species That Occur on San Clemente Island from the Federal Lists of Endangered and Threatened Wildlife and Plants.

(3)   Communications – emails/phone with Mr. Scott Sobiech, Field Supervisor, Carlsbad Fish and Wildlife Office.

(4)   Navy Press Release of January 24, 2023.“Five Species on San Clemente Island Declared Fully Recovered.”Media Contacts.