11-27-2012: Regarding the Fatally Flawed Final EIS

The Final EIS is out, Secretary Salazar came to Drakes Estero, and a Secretarial “decision” is slated to be announced later this week.

DBOC reviewed the NPS Final EIS (FEIS) on the DBOC pending permit extension and just submitted comments to the Secretary.  In the very short time available to review this 1000 page document,  the sections on “sound” were reviewed because it was the only environmental impact determined by NPS to be MAJOR if the farm is allowed to continue.  The NPS science in this $2 million EIS is false – it’s just plain wrong.

For the letter to Salazar from DBOC, click the link below:

2012-11-27-DBOC to Sec Salazar

For the Environ Comments Memo on the Final EIS, click the link below:

2012-11-27-ENVIRON DBOC_FEIS_Soundscape_Comments_Memo

For the Stoel (attorney’s) letter to Salazar, click the link below:

2012-11-27-Stoel letter to Sec Salazar

Your attention is directed to the ENVIRON letter and Dr. Goodman’s analysis.

According to ENVIRON:


“The soundscape impact analysis remains fundamentally flawed. It does not offer sufficiently coherent and correct information upon which to base informed decisions regarding noise impacts from the DBOC facility. The FEIS appears to be based more on pursuing a specific, preconceived result than in factually considering noise generated by the DBOC operations and transmission of such noise to other locations.”


“NPS has spent time and money developing an equally invalid, slanted, and incomplete assessment.”



The noise analysis reported in the DEIS relied on gross exaggerations of DBOC source noise levels based on misuse of data from measurements of other sources.”


NPS’s repeated, unsupported criticisms regarding the quality and utility of the ENVIRON sound level measurements are simply a disappointing attempt to cast doubt where none exists. In lieu of taking actual sound level measurements of the specific equipment whose noise it is attempting to assess, NPS instead opted to criticize but then essentially substantiate and then use the ENVIRON sound level measurement data representing DBOC equipment. At the same time NPS has continued to use an exaggerated range of possible equipment noise levels based on false comparisons with unrepresentative equipment.

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