An independent panel's review of a draft environmental study into impacts an oyster farm is having at Point Reyes National Seashore suggests substantive revisions for the final document.
While the authors note that their comments "should not be interpreted as a conclusion that the (draft Environmental Impact Statement) does not meet NEPA requirements," they also point out that the DEIS features a good amount of uncertainty in the conclusions it reaches.
"Of the eight resource categories, the committee judged that the projected impact levels for seven had moderate to high levels of uncertainty and, for many of these an equally reasonable alternate conclusion of a lower impact intensity could be reached based on the available data and information," the panel noted.
Areas of the DEIS cited as having "moderate to high levels of uncertainty" include oyster company impacts on harbor seals, coastal flood zones, water quality, soundscapes, eelgrass, fish, and wetlands.
Seashore staff have been crafting an Environmental Impact Statement to assess impacts the Drakes Bay Oyster Co. might be having on seashore waters. 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 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.
The outside review that arrived last week is the second on the DEIS. An earlier review, performed by Atkins North America, found that the DEIS was not perfect, but it was an "adequate analysis" in light of the "available scientific information."
The latest review (attached below), by an arm of the National Research Council, was requested by Congress. The report seconds a conclusion reached in a preview review by the national Marine Mammal Commission that it is hard, if not impossible, to currently assess how the oyster company's operations might be impacting, long-term, harbor seals in the estero.
"Indeed, no study worldwide has been designed to assess the impact of disturbance (from mariculture or other sources) on harbor seal haul-out distribution patterns," the NRC report states. "Consequently, 'research that has been conducted in Drakes Estero cannot be used either to directly demonstrate any effects of the oyster farm on harbor seals or to demonstrate the absence of potential effects.'"
Concerning the Atkins review, the NRC panel found that that firm lacked the expertise to fully analyze the DEIS and, as a result, "does not consider the Atkins report to be 'fundamentally sound and materially sufficient.'”
The NRC review pointed to the general lack of scientific literature on the estero as standing in the way of a more thorough DEIS.
To help remedy that dearth of information, the panel, among other things, recommended that in working on the final EIS the Park Service be more clear on how it defines "impact intensities," ie, beneficial, minor, moderate, major; "Qualify each impact intensity conclusion in terms of levels of uncertainty such as those used by the committee; Clearly identify and explain all assumptions made in reaching conclusions concerning impact intensities; Describe potential alternate conclusions as appropriate", and; consider additional mitigations that could be built into a permit extension for the oyster company.