Sources: “America’s Most Crowded Beaches, America’s Top Ten Beaches” Everett Potter, Travel and Leisure July 2012, U.S. Life Saving Association, NY State Parks and Recreation Department, City and County of Honolulu, Emergency Services, Department of Ocean Safety and Lifeguard, Daytona Beach Area Convention and Visitors Bureau, L.A. Beaches and Harbors.
Numbers model generated for 1,157,00 sports license holders times 365 days =422,305,000 annual visitors. (Detailed analysis attached)
Best Available Science model results must be plausible. Motor Vehicle Manufacturer Association v. State Farm Mutual Automobile Insurance Co. 463 U.S. 29, 43 (1983); Okeeffe’s Inc. v. U.S. Consumer Product Safety Commission, 92 F.3d 940, 942 (9th Cir. 1996). See also Congressional Research Service “The Endangered Species Act and ‘Sound Science’” January 23, 2013
In contrast to False Klamath Cover the 10 most populated Beaches are noted for warm sunny weather, calm seas, wide and long beaches, are located in urban areas with extensive parking and major freeway access. A full on comparison of rurally isolated, short, and thin False Klamath Cove Beach and Venice Beach which is the most popular beach in the United States follows. The lack of plausibility for the LOP take assumption should be readily apparent. The issue of impossibility of the assumption needs to be considered and most certainly the accuracy of model predictions appears well below legal standards.