The National Park Service's draft environmental impact statement on an oyster farm at Point Reyes National Seashore was not perfect, but it was an "adequate analysis" in light of the "available scientific information," according to an outside consultant.
"Overall, the reviewers found the analyses to be appropriate, and that there is no fundamental flaw with the larger scientific underpinning of the DEIS," noted the evaluation prepared by Atkins North America. "The identified scientific misinterpretations, or lack of citation of appropriate literature are for the most part minor, and can be rectified if the NPS so wishes. This may also include making some additional adjustments to interpretation, and explicit acknowledgement of the lack of information on some key issues."
Interior Department officials, who released the report (attached below) Monday, said it will help the Park Service improve the final EIS on the Drakes Bay Oyster Co. operations at Drakes Estero in Point Reyes.
“The peer-review accomplished exactly what we were seeking – that is, specific recommendations on how to improve the final environmental impact statement to make it a better science product,” Dr. Ralph Morgenweck, Interior’s Scientific Integrity Officer, said in a prepared statement.
Dr. Morgenweck commissioned the independent peer review of the draft EIS in light of concerns over the science related to Point Reyes.
“We welcome these constructive recommendations that will help strengthen the final EIS,” added Peggy O’Dell, deputy director for operations of the National Park Service. “We will look to address the Atkins Report comments, as well as information contained in the public comments on the draft EIS as we work toward a more comprehensive and thorough final report."
Seashore staff have been crafting an Environmental Impact Statement to assess the oyster company's operations. The issue is timely, as the oyster company's 40-year lease runs out in November, and Congress long ago said the estero should be designated as official wilderness once all non-conforming uses are removed from it.
The draft EIS was released for public review back in December, and the final EIS is expected later this summer.
The interest in the fate of an oyster company that produces between 450,000-500,000 pounds of Pacific oyster meat a year for Bay Area outlets has been fanned by both U.S. Sen. Dianne Feinstein, an ardent supporter of the oyster company and its small workforce, and environmentalists and conservationists who want to see the estero granted official wilderness designation.
To review the DEIS, Atkins North America retained five outside experts: Dr. James E. Wilen, who specializes in natural resource economics at the University of California, Davis; Professor Edwin Grosholz, who teaches environmental science at the University of California, Davis; Professor Dianna K. Padilla, who teaches in the Department of Ecology and Evolution, State University of New York at Stony Brook; Dr. Charlie Wisdom, a privately employed water quality specialist with nearly three decades' of experience, and; Dr. Christopher Willes Clark of the Cornell Lab of Ornithology.
Many of the greatest concerns raised by the outside review centered on socio-economic analyses tied to the Drakes Bay Oyster Co. operations in Drakes Estero at the national seashore.
"... it is my opinion that the methods used to conduct an economic assessment of policy options do not follow accepted economic impact analysis practice," wrote Dr. Wilen. "The basic issue appears to be that the data required to conduct an economic impact analysis has not been gathered.
"That basic data would include, at minimum, measures of the value of gross sales and of the costs of labor and other materials for DBOC. As a result of data deficiencies, the analysis is not able to quantitatively scale the direct first round economic impacts of the DBOC operations in a manner that is meaningful for judging overall economic impacts."
The report also found fault with Park Service conclusions that were either speculative or unsupported by peer-reviewed publications or which were "not reasonable based on scientific evidence."
"It should be noted that data from studies specific to Drakes Estero for birds and other taxa including invertebrates, fishes are cited from three unpublished theses by Harbin-Ireland, Press, and Wechsler," noted Professor Grosholz. "These theses have not produced a single peer-reviewed publication. Therefore, the conclusions from these studies should be viewed as very preliminary and with caution.
"The report relies too much on these studies," he added, though noting that that perhaps was understandable, "since there are really no other studies available."
At the same time, the reviewers noted, the Park Service overlooked dozens of existing, pertinent studies, such as "nearly a decade of studies" on how oysters can impact "water column productivity."
The failure of the Park Service to rely on such studies was a "remarkable oversight," they wrote.