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Point Reyes National Seashore Vs. Scientific Facts
BY Corey Goodman
The quote in the title, from the late Senator Daniel Patrick Moynihan, couldn't have expressed more aptly the difference between opinion and fact in the debate over the impact of the oyster farm on Drake's Estero. Scientific studies generate facts -- called data. Everyone is entitled to his own opinion as to whether the oyster farm should stay or go, but there is only one set of scientific facts. The body of evidence for Drake's Estero is based on over 20 years of scientific studies that have been funded or done by the Point Reyes National Seashore (PRNS).
Last year, the PRNS issued an official report on the alleged damaging impact of the oyster farm on Drake's Estero on their National Park Service web site (www.nps.gov/pore) entitled Drakes Estero, a Sheltered Wilderness Estuary (ref #1). After two decades of collecting data, and many hundreds of thousands of dollars of cost to taxpayers, their lengthy report presented the "facts" supporting their claims that the oyster farm and the surrounding ranches have been degrading the Estero over several decades.
In the May 8, 2007 version of the report given as testimony to the Marin County Board of Supervisors (BOS), the PRNS wrote: "Specifically in Drakes Estero, ecological function has been degraded and altered over the past several decades due to activities associated with oyster farming and ranching." If true, this would be a very serious indictment of the oyster farm and the surrounding ranches. This general claim, with its many subclaims and supporting evidence, has been widely disseminated over the past year, and has been repeated by many local environmental groups as well as the California Coastal Commission.
The public has been led to assume that the PRNS has conclusive evidence from over two decades of studies and reports to back up their claims. Some of the PRNS assertions appeared nearly verbatim in the May 1 issue of the Coastal Post in an article entitled Save Drakes Estero (ref #2) by the Sierra Club of West Marin, the Environmental Action Committee (EAC), the National Parks Conservation Association (NPCA), the Audubon Society, and Wilderness Watch. To repeat and endorse the PRNS claims, apparently without actually seeing the original data and studies, was a dangerous leap. Many of these same misleading PRNS claims have now found their way into a June 5 letter from the California Coastal Commission (CCC) to the owner of Drakes Bay Oyster Company (DBOC) (ref #3). The Coastal Commission writes: "Recent information has come to our attention regarding your offshore aquaculture operations that raises concerns about potential impacts to sensitive resources in Drakes Estero." The misleading claims have been repeated so many times by the PRNS and others that a State agency now appears to assume that they are based on facts.
As a scientist, I am by profession a skeptic of scientific claims made in the popular press, particularly when made by a government agency with an apparent agenda. Scientists don't want someone else's opinion, but rather we want to see the facts ourselves. To this end, I turned to the more-than-20-year history of original research studies to make an impartial analysis of the evidence. There is no ambiguity - the evidence does not support the claims made by the PRNS. Just the opposite - the studies reveal that the Estero is quite healthy.
When I began my analysis early last year, my search for the truth led me to read the Corey Goodman's article for July issue of Coastal Post CONFIDENTIAL DRAFT page 2 original reports, and those reports led me to conclude that the Park's public rhetoric runs counter to the scientific reality. My concern that a government agency appeared to be misleading the public led me to write two reports on my analysis (ref #4 and #5) and testify on May 8 at a hearing of the Marin County BOS. I concluded that there is no compelling scientific evidence to support the claim that the oyster farm and surrounding ranches have degraded Drake's Estero.
It is an unfortunate chapter in West Marin history that the PRNS has disregarded more than 20 years of facts from their own studies and has instead misrepresented these studies to support their political bias. Like all of us, they are entitled to their own opinion, but not their own facts. The PRNS has violated the public trust, and as a result, has cast doubt upon our ability to trust what they say.
I have provided two long reports on my scientific analysis to the Marin County BOS (refs #4 and #5). Both are available as PDF files with the online version of this article. See the bottom of the online version for the references. Bill Wigert, Mark Dowie, and I authored a column in the June 8 issue of the Pt. Reyes Light (ref #6) in which we briefly highlighted a few examples in which the public discourse had distorted the legal or scientific facts. We emphasized two scientific issues - the lack of negative impact of the oyster farm on the eelgrass, and the lack of impact on the harbor seals.
In this article, I will focus on one example -- that oyster feces are the primary source of sediment fill in Drake's Estero -- of how a misleading PRNS claim got repeated by local environmental groups in an article in the Coastal Post, and then subsequently was repeated in a letter from the California Coastal Commission (CCC), when there was never any data to support it, in spite of references to a USGS study. In the official PRNS report (ref #1, quoting the April 1 version), the PRNS wrote: "A USGS researcher stated that a primary source for sediment fill in the estero was from oyster feces ..." They identified the USGS reference as Anima (1990). This same claim was made by a PRNS staff scientist in the April 26 issue of the Pt. Reyes Light (ref #7). This same claim next appeared in the May 1 issue of the Coastal Post in an article entitled Save Drakes Estero (ref #2) by the Sierra Club, EAC, NPCA, and others. They wrote:
"Furthermore oyster feces add sediments to the eelgrass beds of the Estero. Researchers from the U.S. Geological Survey identified the feces of oysters - as much as a metric ton per 60-meter square oyster raft - as the primary source of sedimentation ..." Most recently, this same claim appeared in the June 5 letter from the CCC to the owner of DBOC (ref #3).
Everyone keeps repeating this claim about oyster feces smothering the eelgrass in Drake's Estero. But is it true? The answer is no. The USGS researcher referenced in all of these quotes is Dr. Roberto Anima from the U.S. Geological Survey (USGS), and the study cited is Anima (1991) (incorrectly cited as 1990 in the PRNS report) (ref #8). Anima's USGS study was commissioned by the PRNS to study the impact of the surrounding ranches on the levels of sediments, herbicides, pesticides, and nutrients in Drake's Estero. In the 55 pages he devotes to presenting his data (his "results"), he never mentioned the word "feces" once, because he never studied oyster feces. Anima found that the rate of sedimentation in Drake's Estero is similar to Abbott's Lagoon and other west coast estuaries that lack oysters. He found that there are no significant levels of herbicides or pesticides in Drake's Estero. He found that there are no significant nutrients flowing into the Estero from the surrounding ranch lands. Although the study set out to find negative impacts from the ranches, Anima found none. The PRNS has never told the public the truth about what Anima found because it Corey Goodman's article for July issue of Coastal Post CONFIDENTIAL doesn't support their agenda.
Anima never studied oyster feces. But in his concluding comments, he recommended that in the future, someone should study their impact on the sediments in Drake's Estero. The statement of "a metric ton per 60 meter square oyster raft" (ref #2) is not data collected by Anima. It is not from Drake's Estero and is not from a USGS study, but rather it is from an irrelevant 1955 study of an oyster farm in Japan. In summary, the PRNS misrepresented Anima's study, and others in repeating that claim inadvertently did the same.
On May 21, I spoke with Dr. Anima about his study on Drake's Estero. He told me that the PRNS had misquoted his report. He also told me that a PRNS staffer had called both him and his supervisor the week after I released my first report (ref #3) on May 8. He described to me how he had told the staffer that the PRNS references to his study were wrong. Why did they call his supervisor?
When interviewed by the Light on June 12, the PRNS staffer confirmed, "that Anima did not collect samples looking at oyster feces." Then why did the PRNS misquote him in their official report? Why did they repeat this claim to local environmental groups and the CCC? Why, as this article went to press at the end of June, was the PRNS report with this misleading claim still on their web site? The PRNS did ultimately follow Anima's suggestion to study oyster feces in the Estero. The PRNS funded a study by UC Davis professor Deborah Elliot-Fisk and master's student Angie Harbin, to answer this question. A 2005 summary report by Elliott-Fisk et al. (ref #9) refers to Harbin's thesis when it concludes: "Although pseudofeces from the suspended oysters may contribute to the amount of organic matter below the racks, adding to the system, the amount of organic matter resulting from eelgrass decomposition is likely far greater considering how expansive and dense the beds are within the estuary, making any significant organic inputs from the oysters undetectable in this study (Harbin 2004)."
Elliott-Fisk et al. concluded: "We found the oyster racks to have no pronounced impacts on the eelgrass beds ..." Although the PRNS commissioned and collaborated in these studies, the official PRNS report never mentioned the fact that Elliott-Fisk and her students found no impact of oyster feces on the sediments or eelgrass. In a parallel analysis, another Elliott-Fisk graduate student, Jesse Wechsler, showed (ref #10) that the eelgrass-dependent fish community is thriving and just as abundant in the arm of the Estero that contains the highest density of oyster racks (Schooner Bay) as in the isolated arm without oyster racks (Estero de Limantour) - the arm called wilderness. For the past year, the PRNS has claimed that the oyster farm and ranches have seriously degraded Drake's Estero over the past several decades. At the May 8 hearing of the Marin County BOS, they stated that they had over 25 years of data to back up their claims. My analysis of their scientific studies revealed that there is no compelling evidence to support their conclusion (ref #4 and #5).
Thomas Yeatts, a reporter for the Pt. Reyes Light, independently came to the same conclusion. He published a lead article in the Light on June 15 (ref #11) in which he highlighted the discrepancies between the published scientific research and the Park's report and testimony. When Yeatts confronted Park staff with these discrepancies, a Park scientist told him that the earlier studies were inconclusive, and moreover were irrelevant to today's conditions. But the Park has been referencing those very studies as their 25 years of conclusive data.
The point that Park officials are now trying to argue is that the past two years are different than the previous 25, because there are now up to 9 million oysters in Drake's Estero. The Park claims that much of their data was collected in the 1990's when oyster production was much lower. However, this statement, too, is misleading: Department of Fish and Game data show that there were only 3.6 million oysters in the Estero just one year ago in 2006, and yet there were 5.7, 5.2, 7.1, 8.2, 9.0, 6.9, and 5.6 million oysters respectively in the Estero from 1990 to 1997. So for most of the 1990s there were more oysters in the Estero than there were just last year, and for several years in the middle of the 1990s, there were as many, or nearly as many, oysters in the Estero as there are now. That should hardly make the data from the 1990s inconclusive and irrelevant, as the Park now claims. Catching the PRNS in their public misinformation campaign was only possible because we had the original studies available for verification. When they now talk of new findings, with no published data by which they can be independently verified, can we trust them to tell us the truth?
At the May 8 Marin County BOS hearing, the PRNS staff made a new provocative claim about the impact of the oyster farm on the harbor seals, some of it based on data collected only three days earlier. In the May 11 version of the official PRNS report (ref #1) on their web site, they wrote: "Disturbances to resting and breeding seals increased dramatically in 2007. ... One area where 250 seals nursed more than 100 pups two years ago, have around 50 total seals including around 25 pups in 2007, an 80% decline." This is a dramatic claim of an 80% reduction in harbor seals due to disturbances from the oyster farm. Similar claims have been repeated by local environmental groups (ref #2), and have recently appeared in the California Coastal Commission letter to DBOC (ref #3). The PRNS has widely disseminated this new claim about the 80% decline in harbor seals based on oyster farm disturbances. At the May 8 hearing, the PRNS staff said they had sent this new claim to the federal Marine Mammal Commission. This claim of new data cannot be verified because we do not have access to the data.
Any "data" suddenly produced by a public agency under fire must be considered highly suspect. Since 25 years of available scientific data do not support the claims made in the PRNS official report that has been widely disseminated over the past year, and given that their claims have been exposed as unsubstantiated, the public must be very wary of sudden claims of new data by the PRNS. If the Park makes such claims of new data, the public should insist on being given access to all of the data, not just selected tidbits, should check for bias, confirm that the data are from Drake's Estero, and should insist upon independent analysis of the data.
Toward that end, on May 9th I emailed the PRNS staff scientist asking for the data, and when I got no reply, on May 13th, I submitted a Freedom of Information (FOIA) request, specifically asking for the 2007 data that forms the basis of the Park's provocative new claim about the harbor seals. One month later, the National Park Service sent me their response (ref #12), and it contained none of the requested 2007 data - no tables of number of seals and pups at different locations on different dates - but instead cited a shaky legal loophole (exemption 5) for withholding "the draft records pending the final annual report ..." But I requested research data - numbers that should not be modified - not draft reports. What's more, the Park has already published their claim based on this data in their official report, and made the same claim to the Marin County BOS, the federal Marine Mammal Commission, and the California Coastal Commission.
In summary, the PRNS made new scientific claims in writing, testimony, and official reports, but then used a shaky legal exemption to deny independent access to the research data. Park officials are behaving as if they have something to hide. All of their other claims have been shown to be unsubstantiated. Now they refuse access to the research data that might support or refute their one remaining claim. It is time for us to acknowledge the truth: The emperor has no clothes.
Corey Goodman, Ph.D., is a scientist and member of the National Academy of Sciences. He is former Chair of the Board on Life Sciences, the NAS committee that does many environmental studies for the federal government. He spent 25 years as a professor at Stanford University and the University of California, Berkeley, where he remains on the faculty. He has been a part time resident of Marshall since 1993.
1: Drakes Estero, a Sheltered Wilderness Estuary. Official report of the Point Reyes National Seashore posted on their NPS web site (www.nps.gov/pore). Note: there have been at least four different revised versions of this report posted on their web site (September 2006; April 1, 2007; May 8, 2007; May 11, 2007), but there are likely more.
2: Coastal Post: Save Drake's Estero article
3: California Coastal Commission June 5 letter to DBOC
4: Goodman report #1
5: Goodman report #2
6: Wigert, Goodman, Dowie Light article
7: Sarah Allen Light article April 26
8: Anima 1991
9: Elliott-Fisk 2005
10:Jesse Wechsler 2004
11: Thomas Yeatts Light article on June 15
12: Jonathan Jarvis, NPS Regional Director, letter to CSG on June 13 denying FOIA request for 2007 data
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