allows for the possibility of substitution of other sources of supply which could mitigate to some degree the elimination of production by DBOC.61
Further, with regard to the socioeconomic impact on recreation and tourism, the DEIS notes correctly that (1) visitation of DBOC accounts for a very small share (about 2.5%) of total visitation to the Seashore, and (2) some of these visitors may have been participating in other types of recreation at the Seashore in addition to visiting DBOC and therefore could be expected to continue to come to the Seashore even without DBOC. The DEIS also indicates that the creation of additional wilderness acreage under alternative A might attract some additional visitation. Although the DEIS discusses changes in the number of visits, the DEIS would need to consider the possibility of a change in consumer’s surplus per visit for a scientifically valid cost-benefit analysis.
Under alternative D, which includes construction of a new and potentially more attractive building at DBOC, the DEIS states: “This improvement to visitor experience (described further in the “Impacts on Visitor Experience and Recreation” section), could minimally increase annual visitation to DBOC.”62 The empirical basis for this assertion, that there would be little change in the number of visitors to DBOC, is not clear. A scientifically valid cost-benefit analysis would account for a potential change in the consumer’s surplus per visit as a consequence of the new visitor center.
In addition to consumer’s surplus from recreation, a cost-benefit analysis would also consider the non-use value for an increase in wilderness area. Alternative A extends by 8,530 acres what is the only marine wilderness area (currently at 24,200 acres) on the west coast. As is evident from the public comments submitted on the DEIS, some members of the public have a significant non-use value for the removal of DBOC and the creation of additional wilderness area under alternative A. But others may not.63 A quantitative estimate of the percent of the area population with a positive non-use value for this increment in wilderness area, and of the typical amount of that non-use value, would be a useful addition to the EIS.
As mentioned in Chapter 2 of the committee’s report, there are no gradations for beneficial impacts in parallel with the minor, moderate, and major gradations of adverse impacts. This results in an asymmetric assessment of the no action (A) and action alternatives (B, C, and D) in the DEIS. For instance, under alternative B, DBOC’s operations would be largely unchanged from existing conditions, while under alternative A, DBOC would cease operation. Alternative A “could result in long-term major adverse impacts to California’s shellfish market.”64 Alternative B “would result in a long-term beneficial impact to shellfish production in California.”65 If eliminating DBOC entails a major adverse impact, then maintaining DBOC should lead to a major beneficial impact.
II. REASONABLENESS OF THE CONCLUSIONS, ASSESSMENT OF UNCERTAINTY, ALTERNATE CONCLUSIONS
The conclusions reached in the DEIS might change if a more rigorous, cost-benefit analysis were conducted. The committee makes no finding as to whether the DEIS socioeconomic analysis is sufficient to meet NEPA requirements for such an analysis. However, the committee finds that what is in the DEIS does not constitute a scientifically valid economic analysis. Because the DEIS economic impact assessments were not based on quantitative metrics, it includes inferences and interpretations of impacts that have a high level of uncertainty. For example, even if a person who visited DBOC still continued to visit the Seashore for other types of recreation if DBOC closed under implementation of alternative A,
61 We understand from a DBOC letter dated 6/5/12 that the company provided cost and revenue information to NPS in November 2010, but requested that this information remain confidential. Based on that request, the NPS did not report these data in the DEIS nor use them in the DEIS analysis. In the agricultural economics literature, changes in consumer’s plus producer’s surplus are often estimated by making estimates (or guesses) about demand and supply elasticities and then applying well established formulas based on first-order approximations. Hence, DBOC’s request for confidentiality regarding this data is not an insurmountable barrier to conducting an economic analysis of the change in consumer’s plus producer’s surplus in the California shellfish market.
62 DEIS, p. 401.
63 A 2003 survey of visitors to the Seashore survey asked respondents (Question 17): “Overall, would you like to see the amount of wilderness at Point Reyes National Seashore increase, decrease, or remain about the same?” Of 418 respondents, 43% said increase; 38% said remain about the same; 2% said decrease; and 18% said don’t know.
64 DEIS, p. 393.
65 DEIS, p. 397.