Click on the link above to see the letter.
When the NAS Report came out in 2009, Jon Jarvis, at that time Regional Director for the NPS, gave a series of media interviews (PR light, West Marin Citizen, SF Chron, ABC-KGO, AP and others). His statements posed contradictions and raised a series of questions. The Lunnys asked those questions the attached letter, which went unanswered.
Jarvis and the Park Service didn’t even acknowledge the inquiry, let alone answer it. Follow-ups to Jarvis, Dan Wenk (the NPS Deputy Director at the time) and Will Shafroth (the Deputy Assistant Secretary of the Interior for Fish, Wildlife and Parks at the time), also went unanswered.
Jarvis, along with Neubacher and others worked, not to implement the NAS recommendations, but to challenge the NAS findings with the submittal of a petition to the Marine Mammal Commission (MMC) predicated on the assertion that NAS, with regard to harbor seals, got it wrong.
The Sierra Club-NPCA petition to the MMC stated conclusions, but failed to set forth any level of detailed justification of what NAS got wrong, why it was wrong and why or how NPS had data and evidence to support their-oft-repeated (but never defined) claims of environmental harm. That NPS “data and evidence” still remains elusive today.
Judge for yourself. How did the Lunny family respond to the NAS Report? Professional? Responsible? Reasoned? How did NPS respond? Compare. Then ask, by what authority does NPS “blow off” the Lunny letter?”
When NPS (Jarvis) failed to respond, did they/he violate a stack of policies, rules, guidelines and Codes? How about the Presidential ExOrder on Cooperative Conservation? What about the NPS Code of Scientific and Scholarly conduct? How about Obama’s directives on transparency? How about plain ol’ common courtesy? How about manners? There’s a conflict – of course there’s a conflict. That’s a reason to engage, talk, come together – work things out. Not NPS. Delay, drag-out, drive up costs (remember, Don Neubacher once told the Lunnys – “I don’t have to pay for my attorneys…”).
NPS – Jarvis – had no interest in upholding, adhering to or even considering the NAS report. It’s conclusions on cultural issues represented a serious problem for them. Same with harbor seals. NAS, with the agenda manipulated by NPS and the table hopelessly tilted, still came down hard on NPS. So, the Park Service had to dispatch – get rid of — the NAS report. They had to purge it. And they did. Step one. Go to the Marine Mammal Commission. Step two – the NPS Draft EIS eliminates the NAS Report that eliminated it – in its entirety (even though Congress, by law, directed them to be guided by it). Step three – just ignore the Lunnys.
Fast forward – what is known about the EIS? Consider:
- NAS Report – EXCLUDED.
- 281,000 secret spy camera photos (and logs) – EXCLUDED.
- 99% of harbor seal disturbances (all non-oyster farm related) – EXCLUDED.
- All of Dr. Goodman’s papers, reports, letters, Power Points (not one cited in the 37-page, 400+ item DEIS References) – EXCLUDED.
- Both of Dr. Sarah Allen’s studies revealing harbor seals habituate to disturbances they consider non threatening as well as . - EXCLUDED
That’s just for starters. Excluding the inconvenient is the real theme of the DEIS.