“Once again, NPS created a new hypothesis of harm, in this case the supposedly highly negative impact of sound on wildlife and wilderness from Drake’s Bay Oyster Company. However, this latest allegation cannot survive even the most cursory examination without collapsing in a way that raises serious questions as to the integrity of Jarvis’ management of Park Service Science……..Worse, the NPS had research data in hand that directly discredited their hypothesis of harm.
This is yet another failure by NPS to follow a scientific procedure, as they should have at least tested their hypothesis of harm against the actual, available sound data. This pattern is identical to the incident several years ago when the Park Service set up a hidden camera in approximately the same location as the Volpe microphone. When it failed to substantiate the previous harm hypothesis–that oyster operations were disturbing seals–they concealed the program from the Marin County Board of Supervisors, DOI IG, the National Academy of Sciences and the Marine Mammal Commission panel. NPS had exculpatory evidence and direct contradictions in hand, and either failed to consider this material or simply ignored it and concealed it from others just as, in this case, they withheld the Environ sound data from peer reviewers.
Dr. Goodman’s investigation revealed that the DEIS made numerous claims that are internally contradictory. For instance, NPS used three different standards for sound levels, finally selecting one that is neither cited in the Volpe report nor used in any other NPS EIS reports. The DEIS then claims that it is ‘using the accepted formula’ that sound decreases 6 decibels with every doubling of distance from the source. However, this NPS statement is contradicted by DEIS’ table 4-2, used with the actual Environ data as the basis for the Times graphic. Dr. Goodman’s Complaint notes significant errors in the NPS sound-distance calculations. This miscalculation also shows that the unbelievable NPS claim–that a hand-held air hammer is audible at 3.3 miles–becomes ludicrous when corrected, indicating that NPS believes the hammer should be audible at a distance of over 10 miles. There is no scientifically acceptable way that actual sound data could be manipulated to support the NPS hypothesis of harm.
May 8th is the fifth anniversary of NPS claims to the Marin County Board of Supervisors that Lunny was an environmental criminal who had caused a massive loss of seal pups. In the ensuing five years, not one of the NPS hypotheses of harm has held up to millions of dollars of taxpayer-funded investigation by outside sources such as the National Academy of Sciences or the Marine Mammal Commission. Now, NPS behavior has totally invalidated their DEIS which–as Senator Dianne Feinstein said in a recent letter to Salazar–appears fraudulent. The Department of Interior IG and the White House Office of Science and Technology Policy should take this case from NPS and those involved within DOI, judge their conduct against the standards set forth in President Obama’s March 9, 2009 executive order on scientific integrity, and proceed as the facts, laws and accountability dictate.”
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