Aliance of Communities for Sustainable Fisheries
P O Box 1309, Carmel Valley, CA 93924 (831) 659-2838

January 6, 2003

PISCO, UCSB, Marine Science Institute, Santa Barbara, CA 93106-6150

PISCO, Stanford University, Hopkins Marine Station, Oceanview Boulevard, Pacific Grove, CA 93950

PISCO, UCSC, Long Marine Laboratory, 100 Shaffer Road, Santa Cruz, CA 95060

PISCO, Oregon State University, Department of Zoology, 3029 Cordley Hall, Corvallis, OR 97331

To Whom It May Concern:

We are writing to express our concern over several recent actions by the Partnership for Interdisciplinary Studies of Coastal Oceans (PISCO). We now wonder if PISCO is moving away from being a science-based organization, and becoming, at least on the topic of Marine Reserves, an advocacy group. We wonder if PISCO realizes the impressions that certain recent actions on its part have created among the public who have been following the debate over Marine Reserves. Society expects science to be objective, fair and impartial. We therefore point out that advocacy for a theory that results from or causes a loss of objectivity on a topic that affects so many people and resources can have serious consequences, such as:

1. Social and economic damage
2. Fail to deliver intended benefits
3. Lead to actionable abuse of due process by government and advisory groups that rush into such MPA policies at a time when the scientific rationale for them has fallen into serious question
4. Cause unintended harm to fishery resources, which diminishes a basic food supply for our country

We hope that PISCO and the greater science community understands the weight of responsibility for its role in providing objective information in the Marine Reserves decision-making process.

Our first area of concern lies in the publication of “The Science of Marine Reserves”, which purports to present the latest and most complete science on this topic. We have been following the science well enough to know that the wave of support for the widespread use of Marine Reserves and MPAs generally to solve a host of ocean ills has already passed. The next wave that is building is of more critical thinking as to: cautions and limitations that result from their use as a fishery management tool; for their ability, or lack of, to successfully restore a native biodiversity; their potential harmful impacts on neighboring areas; and, the need for more research to be done regarding unintended or unexpected consequences. This is not just the opinion of a bunch of fishermen; we know respected members of the science community are beginning to challenge some of the claims made about the benefits of Marine Reserves. There is, however, very little discussion of criticism or competing theories regarding the effectiveness of Marine Reserves in “The Science of Marine Reserves.” These omissions are obvious to informed readers, and we fear that PISCO not only loses credibility, but will be seen as rushing to judgement before its case falls apart under critical peer review.

Of particular concern is the credit given to Dr. Ray Hilborn, of the School of Aquatic and Fishery Sciences at the University of Washington, for his review and comments on this PISCO report. We know that Dr. Hilborn does support the use of Marine Reserves in certain circumstances. However, he has also been one of the scientists who is of the second wave, offering critical evaluations of Marine Reserves, particularly as to their benefit and costs in fishery management regimens and impacts on neighboring areas. He has also challenged many of the case studies cited by Marine Reserves supporters as not really being on-target to substantiate actual benefits. We have since learned that Dr. Hilborn’s comments, solicited by PISCO, were in fact received, but not incorporated in the PISCO document. PISCO should consider that it can seem misleading to issue a statement that thanks Dr. Hilborn and credits his comments, leading to the impression that he supports this report, when in fact he expressed concerns. A copy of a statement issued by Dr. Hilborn is attached for your review. It suggests that he is among the informed readers who view the PISCO report as an advocacy instead of a science-based document.

Also not included, even by mention or in the bibliography of resource materials, is the study done by Dr. Robert Shipp, Chair of the Marine Sciences Department at the University of Southern Alabama. Dr. Shipp has also served for nine years on the Gulf of Mexico Fishery Management Council, including two terms as Chair. His study is of approximately 350 species of fish, including most West Coast fished species. He concludes that Marine Reserves are of no benefit, and may even be of negative benefit, for approximately 98% of these fish stocks as a fishery management tool. The fact that this study, which is well known in the science community, was not even mentioned in the PISCO report, also makes informed readers wonder if the PISCO authors are interested in. CONTINUED