The GGNRA DEIS Ignores Independent Studies Showing That Off-Leash Recreation Does Not Impact Plovers

In its Draft EIS, the GGNRA continues to ignore recent scientific atudies whose findings do not serve the purpose of eliminating off-leash recreation.

One example is a U.C. Berkeley Environmental Sciences study presented by Megan Warren on
May 7, 2007 which concludes that within the GGNRA, the feeding of the Western Snowy Plover does not appear to be negatively affected by human and pet recreation. This is highly significant. Because the Western Snowy Plover does not nest or breed at Ocean Beach or Crissy Field, its primary essential activity is foraging and feeding. If human and pet recreation does not negatively affect those activities, there is no need to restrict recreation in these areas.

The abstract states, in pertinent part:

Recreation Disturbance Does Not Change Feeding Behavior of the Western Snowy Plover

"The Western Snowy Plover (Charadrius alexandrinus nivosus) is a small shorebird that has many scattered wintering populations along the Pacific Coast of the United States, including several in the Bay Area.

"This species has been listed as threatened since 1993 under the federal Endangered Species Act of 1973. For this study I measured disturbance rates, types, plover responses and feeding time in three different sites in the San Francisco Bay Area to explore the link between recreation disturbance and feeding behavior. I predicted
that as frequency of disturbance increased, the birds would spend less time actively foraging and more time alert. However, data showed no significant relationship between feeding behavior and direct disturbance by human recreators. Instead, I now predict that recreation has a more indirect effect on the western snowy plover feeding behavior. Future research should focus on indirect effects of recreation, such as habitat disturbance and food source quality."

One must seriously question the efficacy of the DEIS in completely ignoring such studies and instead relying upon the findings of its own staff, which are not scientifically viable but are inherently biased.