Commenting on the Draft EIS for the
Drakes Bay Oyster Company Special Use Permit
Comments are due December 9, 2011 at midnight MST.

Support the Collaborative Management Alternative
You are not limited to a single comment, so even if you've already commented, you can still send in a comment supporting this alternative.

As you know, none of the DEIS alternatives are acceptable. Since the comment period encourages development of alternatives that meet the purpose and need, but that have not been considered, we are submitting the "Collaborative Management Alternative."

We urge you to send a comment to the NPS telling them you support this alternative and to adopt it as the preferred alternative in the Final EIS.

This alternative meets the purpose and need of the DEIS and the 2009 legislation that authorized the Secretary of the Interior to grant DBOC a Special Use Permit (SUP) with the same terms and conditions as the Reservation of Use and Occupancy that expires in 2012, modified to include recommendtaions of the National Academy of Sciences [NAS} Report on mariculture in Point Reyes National Seashore.

The Collaborative Management Alternative supports a landscape that is ecologically and economically sustainable. It is consistent with the natural resource management provisions in the PRNS General Management Plan, and enables PRNS to collaboratively integrate ecosystem science and natural and cultural resource management.

Read the alternative here. You may also submit this summary with your comment.

More on Commenting

The purpose of public review of a Draft EIS is to gather comments from individuals, groups, and agencies regarding the adequacy of the draft EIS in addressing the purpose, need and objectives, environmental issues of concern, and the sufficiency of the overall analysis.

Comments should point out:

• errors in analysis that may affect the outcome;
• new information that would change the analysis and conclusions;
• parts of the document that need to be clarified;
• an alternative that meets the purpose and need statement but has not been considered.

Our review of the draft EIS shows it to be a flawed, biased document.  We offer the following list of topics for guidance as you prepare your comments.
 
1.  The historic cultural role of the oyster farm in West Marin is not adequately addressed. The EIS must assess the cultural impacts of eliminating an institution that has been in operation for 100 years, and that has served park visitors, local restaurants and the local food shed.
 
2.  Environmental benefits are misrepresented.  PRNS has been rebuked several times for misrepresenting the facts about the environmental benefits of oyster farming. The draft EIS misrepresents those facts again, calling the removal of the oyster farm the “environmentally preferable” alternative.  The DEIS fails to address the important ecological services provided by oysters, including filtering water. Further it does not address the environmental impacts of replacing a local, sustainable food source with 35,000 pounds of oysters flown in from Asia each week. Comparisons of the carbon footprint of the existing food source with the replacement food source must be analyzed in the DEIS.

3.  Economic impacts are not adequately addressed.  The DEIS mentions that removing the oyster farm would cause “major, long-term, adverse effects to the California shellfish market” but does not provide a complete analysis of these impacts, nor does it include these impacts in the overall analysis. The EIS must assess and address the economic impacts of eliminating the production of 50% of California’s oysters and the subusequent impact on the local, state and national economy. Further, the DEIS does not analyze the impacts of eliminating one of the largest employers in West Marin.
 
4.  Socioeconomic impacts:  The DEIS fails to address the impacts on the oyster farm's approximately 50,000 visitors annually who enjoy the oysters and the interpretive services provided by Drakes Bay Oyster Company. Visitors to the oyster farm represent a wide range of incomes, races and ethnicities, some of whom might not otherwise have any connection to the National Park System. The National Park Service itself actively searches for ways to increase access to the National Park System for underserved communities. If DBOC's Special Use Permit is denied, these underserved communities would be impacted. The DEIS must address the subsequent impacts to these visitors and how these impacts will be mitigated.
 
5. Impacts to local habitat restoration efforts and endangered species are not addressed.  The oyster shell biproduct from the Drakes Bay Oyster Farm cannery is a critical and sole resource for reestablishing native oyster beds, and restoring Least Tern and Snowy Plover habitat in San Francisco Bay. The California Least Tern is a U.S. federally listed endangered species and the Snowy Plover is in decline due to habitat loss. If Drakes Bay Oyster farm is shut down, the restoration operations would likewise be shut down. The draft EIS does not address the impacts to wildlife or the environmental issues surrounding the loss of these restoration efforts.
 
6. The DEIS does not consider existing management policies. The current General Management Plan for Point Reyes National Seashore, adopted in 1980, strongly supports the continued operation of the oyster farm, as do all of the relevant Marin County planning documents.  The DEIS does not address how it can bypass the existing General Management Plan and Marin County’s planning processes. The failure to address these issues points to arbitrary and capricious actions on the part of PRNS.

7. There is no science upon which to base the supposed impacts. For a good review of the lack of data, see Dr. Corey Goodman's October Presentation on the DEIS. You can also learn more from his presentations on his Youtube Channel.
 
Thank you for your interest in this process and for your review of the DEIS.  If you have questions or comments contact us at:  alsamarininfo@gmail.com.