“In the Drakes Estero DEIS, no reasons are given for selecting the jet ski sound, and the even more distorting substitution of construction-equipment sound data for actual oyster equipment. This fact places these questions before the IG’s investigation: who at NPS or VBH is responsible for the decision not to make actual measurements of the DBOC equipment; who selected the 1995 Jet Ski and other imported data; and what was their rationale for doing so.
The imported data selected for the DEIS produces results claiming to show negative impact over the entire estero, covering all the seal haul-out areas. However, NPS has run through five generations of hypotheses of harm to establish a negative link between oyster-farm activity and seal populations but failed in every instance.”
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