cleaning up the discharge, as called for in CEQ's National Contingency Plan. 

 By the time the Service representative is actually requested to go to the 

 site of the incident, substantial quantities of pollutant may have escaped 

 and significant numbers of birds or other wildlife may already have been 

 contaminated. Should a spill occur in any area previously determined to 

 be particularly valuable to fish or wildlife and sensitive to spills, the 

 Service should dispatch a person to the scene immediately to evaluate the 

 potential impacts on wildlife. That person should make recommendations both 

 to the OSC and the Service field level or regional spill coordinator as to 

 what actions need to be taken. This person may be the manager of a nearby 

 refuge; a biologist with Wildlife or Fisheries Assistance, Ecological Services, 

 or Biological Services; a special agent; or any other qualified employee. 



After a preliminary assessment of potential threats to birds or other 

 wildlife is made, and if significant threats exist, preplanned actions can 

 be set into motion to effect a smooth, well -coordinated response. Too often 

 we have waited to be called by the OSC and told what to do. The Service 

 must take the offensive, be aggressive, and lead the response from the outset, 

 at least, so far as wildlife aspects are concerned. We should advise the 

 OSC what needs to be done, for example, to protect birds and their most 

 critical habitats, and we should establish the necessary liaison with those 

 interested in salvaging and treating oiled birds. We cannot take a position 

 of "wait and see if someone else will do it." If it appears that significant 

 numbers of birds may be involved, we should take whatever actions are necessary 

 immediately to prevent birds from becoming contaminated. Decisions must 

 be made on the best methods to accomplish this, which might include deploy- 

 ment of audio or visual scaring devices, baiting birds away from the impacted 

 area, or, if feasible, covering the slick with some sort of screening device. 

 Chemical dispersants to emulsify the oil may even be considered in extreme 

 cases, but under normal circumstances, EPA will determine the use of dispersants. 



As bird dispersal activities are initiated, bird collection and cleaning 

 stations, and personnel to staff them, should be activated as a precaution 

 in case birds do become contaminated. Again, the Service field coordinator, 

 working directly with state wildlife personnel, is responsible for establishing 

 cleaning stations or for seeing that cleaning stations are established when 

 necessary. Regardless of who may volunteer to assist us, the Service is 

 ultimately responsible and accountable for this function. As I said before, 

 we do not have a choice here. The better we organize a bird cleanup operation 

 in advance of a spill, especially through local conservation groups, the 

 more efficient the operation will be during an actual incident. Having the 

 stations, equipment, and people identified and located prior to a spill is 

 paramount to a smooth operation during a spill response. 



All of these steps must be taken within hours, not days, after a spill 

 occurs; early warning is the key to minimizing damage to wildlife and their 

 habitats. We need to put this advice into practice during spill incidents 

 and effect our response as rapidly as poss-ible. Our field coordinator must 

 be able to advise the On-Scene Coordinator concerning all matters relating 

 to protection of fish and wildlife and their habitats, as well as to what 

 equipment and personnel are required to provide adequate protection. 



