Information Quality Complaint to National Park Service | Cause of Action.
Summary of Complaint
To comply with applicable minimum information-quality standards, all scientific information that NPS disseminates in publications such as the DEIS and Atkins Peer Review Report must be, among other things, accurate and timely; based on the best available science and supporting studies and the most current information available; highly transparent; supported by reliable data, including on-site data when required by law; consistent with sound and accepted scientific practices and policies; evidence-based; reproducible by qualified third parties; and objective and unbiased in terms of both presentation and substance.
NPS can only claim that Alternative A is the “environmentally preferred alternative” because it flagrantly and repeatedly failed to comply with these minimum information-quality standards. Conclusions in the DEIS that DBOC causes “major” long-term adverse impacts on Drakes Estero’s “soundscape” and “wilderness” are based on inaccurate, nontransparent, false, and misleading data and analysis that violates NPS’s information-quality guidelines, as are claims that DBOC causes “moderate” long-term adverse impacts on Drakes Estero’s “harbor seals,” “birds and bird habitat,” and “visitor and recreation experience.” If the DEIS is corrected to meet basic minimum information-quality standards, it becomes clear that DBOC’s operations do not have long-term adverse impacts on Drakes Estero’s environment.
Drakes Bay Oyster Company & the National Park Service. Watch the video, "THE FRAMING OF AN OYSTER FARM" at http://vimeo.com/52331881 