Friday, January 24, 2014
The NPS/GGNRA Original And Supplemental EIS Were Promulgated With Junk Science
Courtesy Ocean Beach DOG:
"We have some enhanced information for you all on the web site. Many of you have been aware that we have been emphasizing that your comment should include the complaint that the DEIS/SEIS does not include site-specific, peer-reviewed scientific evidence to support their proposed changes to “protect the resources”. We knew based upon the SEIS that this was important, and in fact essential. However, we have had a difficult time researching the legal basis for this. We also have had the DOI out to our web site almost every day. So we knew something we were saying was problematic for them. Finally, after accessing some of the cached copies of some web pages that came up empty before, we hit pay-dirt.
We have now located the “smoking taser” for our case against the GGNRA!!! It appears that in 2005, about the time when Judge Alsup was reinstating the 1979 Pet Policy, a law promulgated by the Office of Management and Budget was taking effect. The law mandates that all Federal Agencies who release scientific information to the public MUST subject the scientific study/information to peer review BEFORE releasing it to the public. We now have also found the Department of Interior’s response to this mandate, and the NPS response as well. We have found the handbooks and it is clear that the GGNRA/NPS/DOI has not followed the law AND the remedy would be withdrawal of the scientific information entirely. We want to make it clear that the GGNRA studies (e.g., “The Hatch Reports”) would not have survived peer review. The GGNRA knows this. Therefore, the “emergency” closure of Ocean Beach and Crissy Field in 2008 is ENTIRELY UNLAWFUL!!! The study Daphne Hatch released as part of their support for closure was NOT peer-reviewed, and OBDOG raised the appropriate objections in our comment on the proposed closure. That is why we believe it is completely appropriate, and lawful, that the GGNRA must return to the original 1979 Pet Policy. The studies/data presented in the DEIS were not peer reviewed. In fact, they were completely omitted in the SEIS because they did not comply with the law!!! The fact that the GGNRA/NPS/DOI did not withdraw the entire proposed 2013-2014 DMP is in violation of the law. AND THE GGNRA/NPS KNOWS IT!
Please take the time to read the new section titled “The Smoking Taser” which we added to the DEIS/SEIS section of the OBDOG web site: http://oceanbeachdog2.home.mindspring.com/id32.html. It is lengthy, fairly technical and perhaps a bit boring, but if you really care about the disposition of GGNRA off-leash, consider it a must read. One warning: please be patient as the web site seems to be running VERY slowly as of late.
Although the GGNRA should reinstate the original 1979 Pet Policy, history has shown that to be unlikely. Therefore, it may require judicial or Congressional intervention to get us back where we should be. Also, this underscores the need for a legal defense fund, which, to date, everyone seems to be ignoring."