Below is an economic impact study that heavily influenced the final 2013 ISDRA RAMP. ASA submitted it as part of the ASA RAMP comments.
It serves as a formal critique of a draft economic report prepared by Industrial Economics, Incorporated (IEc) for the U.S. Fish and Wildlife Service regarding the designation of critical habitat for the Peirson's Milk-vetch at the Imperial Sand Dunes Recreation Area (ISDRA).
Key points of contention include:
Underestimation of Welfare Loss: McClure argues the IEc's estimated welfare loss of $85.9 million is too low because it uses a simplified "benefit transfer" method.
Flawed Comparisons: IEc relied on studies of OHV use in North Carolina and Utah, which McClure contends are not comparable to the "extreme sport" of sand duning at ISDRA.
Lack of Substitute Sites: McClure highlights that while the IEc report mentions other sites, none offer the same scale or unique experience as the 132,870-acre ISDRA, meaning there are no true "substitutes" for these users.
Ignored Qualitative Benefits: The critique emphasizes that IEc failed to quantify the strong sense of community and family bonding that ISDRA visitors derive from the area.