Scientists Weigh In

To watch the video: “The Framing of an Oyster Farm”,  click the link or copy and paste it into your web browser:


01-24-15 ProPublica: Bad science from the Park Service

Kevin Lunny has owned and operated the Drakes Bay Oyster Company in a Pacific inlet north of San Francisco since 2005. This winter, an 80-year tradition of shellfish farming in the estuary came to an end when the National Park Service shut Drakes Bay down, claiming the company was a “heavy industry that imperiled the park’s wildlife.” While some environmentalists say “good government prevailed,” an investigation by Newsweek found that the science-as-evidence used to close down Lunny’s farm was either altered or bad. Newseek via @CivilEats

Bad Science, Crazy Mining Laws, and Childcare Horror Stories, #MuckReads: A weekly roundup of investigative reporting from ProPublica, “an ongoing collection of the best watchdog journalism” 


1-23-15 U.S. Department of the Interior And Environmental Lobbyists Conspire To Suppress Science

“Salazar instead ignored science completely and manipulated reports and definitions to suit an environmental agenda.”

For the rest of this article, go to:


01-22-15 Pt Reyes Light: Seal Expert Says Federal Agency Ignored His Findings, by Samantha Kimmey

 “A scientist told a national magazine that a federal agency changed his analysis of photographs of Drakes Estero to justify a claim of environmental harm against Drakes Bay Oyster Company, which ceased operations last month….

In a Newsweek story published online last Sunday, Mr. Stewart said, “It’s clear that what I provided to them and what they produced were different conclusions and different values.” He added, “In science, you shouldn’t do that.” 

For the rest of this article, go to:



01-18-15 NEWSWEEK, Tech & Science: The Oyster Shell Game – “YOU’VE BEEN SHUCKED”, by Michael Ames,


The Oyster Shell Game


Some SIGNIFICANT EXCERPTS from the article (with emphasis added)

The idea that Lunny’s farm was a heavy industry that imperiled the park’s wildlife was, for a while at least, the core reason for evicting him. But for the U.S. Department of the Interior (DOI), the only agency with the power to enforce full wilderness protection, there was one problem with this argument: PROVING IT!!! 

For the rest of this article, go to:


12-24-14 West Marin Citizen, Opinion, Dr. Jeff Creque: “Our actions matter…on our… path to self-destruction”

“I have spent the past 35 years exploring… the many challenges attendant to producing food in a manner that is ecologically benign or, at its best, beneficial. …. it was not until I watched the evolution of the Drakes Bay Oyster Farm under the stewardship of the Lunny family that I came to fully appreciate how closely the Farm approaches perfection as a truly sustainable food production system.

For the complete article, go to:


11-13-14 Point Reyes Light: Opinion by Dr. Laura Watt, Ranchers have “good cause for concern”

“Last week an opinion piece in this newspaper suggested that environmental groups, including the Center for Biological Diversity, might be gunning for the Point Reyes National Seashore’s dairy and beef ranches through the recent Ranch Comprehensive Management Planning process. The authors, and others who support the continuation of ranching, may have good cause for concern. This would not be the first time advocacy groups have used planning processes to target the leased ranches…”

For the complete article, go to:



The park, the E.A.C., the N.P.C.A. and others have claimed they are not trying to get rid of the ranches. We are skeptical. If they mean what they say, then we ask Jon Jarvis, Neal Desai, Gordon Bennett, Amy Trainer and Jerry Meral to make the following pledge to the community: I promise that neither I nor any organization I am a part of will ever participate in legal action to eliminate or restrict the ranches on Point Reyes; and if such legal action is ever taken, I will do everything in my power to vigorously defend the ranches.

If they don’t take the pledge, watch out. Our ranches are about to disappear.

For the complete article, go to:


05-14-13 Russian River Times, John Hulls on Gorden Bennett’s troubles with telling the truth

What lies in Drake’s Estero

….The “smear Lunny” campaign began in the spring 2006 Sierra Club Yodeler magazine by Gordon Bennett, then Chair, Marin Chapter.  Even an internet review will show that much of the campaign against the Lunnys originated with one individual, plus the direct involvement of a then-retired major Sacramento political player, active in West Marin after leaving his job with a major environmental lobbying group under a cloud.

Anything beyond the most cursory examination would find multiple cases of hidden and misrepresented data, not to mention deliberately altered photographs used without permission, known false statements about endangered species and the creation of a new hypothesis of harm each time previous claims were discredited.

For the entire piece, go to:


May 2014 Nat’l Geographic Cover story: EAT Serving more than 7 billion every day

The link to the article:  Feeding 9 Billion | National Geographic.


To feed our hungry planet, we must change the way we farm – and the way we think.

By Jonathan Foley

“When we think about threats to the environment, we tend to picture cars and smokestacks, not dinner. But the truth is, our need for food poses one of the biggest dangers to the planet.”

from pg 35 of the hard copy


Where will we find enough food for 9 billion?

A Five Step Plan to FEED THE WORLD

For the rest of the story, click on or copy and paste the link  below into your web browser:


04-09-2014 NOAA: Oyster aquaculture could significantly improve Potomac River estuary water quality

April 9, 2014

Excerpts from the article:

New NOAA and U.S. Geological Survey study published in the journal Aquatic Geochemistry.

The team sought to assess how shellfish aquaculture – specifically oyster aquaculture — could be used to remove nutrients directly from the water, complementing traditional land-based measures.

  • Oysters… can clean an enormous volume of water of algae which can cause poor water quality.
  • All of the nitrogen currently polluting the Potomac River estuarycould be removed if 40 percent of its river bed were used for shellfish cultivation,
  • A combination of aquaculture and restored oyster reefs may provide even larger overall ecosystem benefits.
  • A smaller area could still provide great benefits if aquaculture leases were approved.
  • According to the study, if only 15 to 20 percent of the bottom was cultivated it could remove almost half of the incoming nutrients.
  • When a body of water becomes enriched in dissolved nutrients …  nuisance algal blooms [occur]… often result in depletion of dissolved oxygen and the loss of sea-grasses.
  • This alternative approach to water quality management has the potential to
    • address legacy pollution,
    • provide a marketable seafood product
    • enhance local economies with additional income to growerswhere growers would be paid for the water cleaning services done by their oysters.

Historically, waters of the Potomac and other Chesapeake region estuaries were filtered by oysters, but as their populations declined so did their filtration capabilities. This resulted in increased concentrations of nutrients and related water quality concerns, such as algal blooms and low dissolved oxygen. Dissolved oxygen, a key measure of water quality, is something fish and other aquatic species can’t survive without.

“The most expedient way to reduce eutrophication in the Potomac River estuary would be to continue reducing land-based nutrients complemented by a combination of aquaculture and restored oyster reefs. The resulting combination could provide significant removal of nutrients and eutrophication impacts directly from the water column, and offer innovative solutions to long-term persistent water quality problems.”

Flowing into the Chesapeake Bay, the Potomac River is the fourth largest river on the Atlantic coast, with more than six million people living in its watershed. The NOAA and USGS research about human influences on water quality found that the effects of high nutrient levels have not changed overall since the early 1990s. There are, however, some signs of improvement, such as decreased nitrogen loads from the watershed, increased dissolved oxygen and decreased algal blooms in the upper estuary, and continued regrowth of seagrasses.

The researchers believe the results of the study may be useful on a broad basis, as there are other river-dominated estuaries in the Chesapeake region and elsewhere along the U.S. coastline that could support shellfish aquaculture.


For the complete article go to:







George Whitehurst Berry will host

  • ELECTED MEMBER, NAS Dr. Corey Goodman (who uncovered the scientific misconduct of the PRNS)

  • COLLEGE OF MARIN PROF. Joe Mueller (who disagrees with Dr. Goodman)

Both have been on Sedona Dreams Radio previously but separately.

Both are invited for tonight’s 9:00 PM hour to discuss / debate the science behind the DBOC situation (see emails between George and Joe below – NOTE: Dr. Goodman has already committed to being on the show tonight)

Listeners can simply go to & click on the “listen live” link on the home page when my show comes on. Listeners can also click on the “schedule” link on the home page to see when the Sedona Dreams show begins. You may also call one of the numbers listed below.

For more on this click on or copy and paste the below link into your web browser:


12-05-13 WMC Opinion: Final Paragraph: Fear of Facts by Dr. Corey Goodman

Seven years into this debate, the pattern is clear: I keep offering to discuss the data—a normal part of the scientific process—and people on the other side steadfastly refuse. This, to me, is evidence that they are advocates and not scientists. As the court case moves forward, expect more alarming claims. But don’t expect them to have any more merit than the many previous false, and retracted,claims. Science, after all, is about  debate and discourse, not twisting facts to fit a preconceived ideology. Scientists have three words for such behavior: fear of facts.  

Corey Goodman, a biologist, University of California, San Francisco faculty member and elected member of the National Academy of Sciences, lives in Marshall.

For the full article click on or copy and paste the link below to your web browser:


12-05-13 WMC Opinion: Fear of Facts by Dr. Corey Goodman

When I was a student at Stanford, one of the things I enjoyed most was the way scientists debated facts. No claim could be made without data to back it up, and all data were subject to robust scrutiny and examined for holes and errors. That was how we were taught to seek truth. We were encouraged to ask tough questions, and were taught that science is just as much about disproving old hypotheses as deriving new ones. It was the same culture of science I taught to my students throughout my career. 

Thus it came as a shock when, nearly 40 years later, I first got involved in the oyster farm debate and discovered that none of the National Park Service scientists or their local supporters wanted to discuss the data. At Supervisor Steve Kinsey’s request, I examined that data. As I reported at the county hearing on May 8, 2007, the data did not support their accusations.

For the complete article, click on or copy and paste the link below into your web browser:


08-25-13 Marin Voice: Up-to-date Eco Theory by Dr. J. Creque

Yet efforts now underway to restore oysters to San Francisco Bay, and estuaries around the world, offer pertinent examples of how shellfish, as ecosystem engineers, can improve water quality, add to structural diversity in the estuarine system, and play a critical role in enhancing ecosystem biodiversity, productivity, and resilience.


Aldo Leopold once argued that the first rule of intelligent tinkering was to save all the pieces. Saving the Drakes Bay Oyster Co. is one simple, sane step in that direction.

For the complete article, click on, or copy and paste the link below into your web browser:


08-03-13 Marin Voice, Science shows oyster farm doesn’t harm estero’s ecology

by Dr. Corey Goodman

JOE MUELLER’S July 31 Marin Voice column (“Doing what’s right for the ecology”) is surprisingly devoid of facts. Almost everything in his column is contradicted by the scientific literature on Drakes Estero.

Mueller says oysters rob nutrients from marine wildlife. But a series of studies from UC Davis found just the opposite — marine invertebrates and fish are thriving in Drakes Estero. The National Marine Fisheries Service (responsible for protecting harbor seals under the Marine Mammal Protection Act) reported the seals are healthy and not being disturbed.

The National Academy of Sciences found no evidence for any major environmental impact of the oyster farm on Drakes Estero.

For the complete article, click on, or copy and paste the link below into your web browser:


06-27-13 UC Davis Study finds Cattle Grazing/Clean Water Compatible on Public Lands

“Cattle grazing and clean water can coexist on national forest lands, according to research by the University of California, Davis.”

Cattle grazing and clean water are compatible on public lands, new study finds

June 27, 2013

The study, published today in the journal PLOS ONE, is the most comprehensive examination of water quality on National Forest public grazing lands to date.

“There’s been a lot of concern about public lands and water quality, especially with cattle grazing,” said lead author Leslie Roche, a postdoctoral scholar in the UC Davis Department of Plant Sciences. “We’re able to show that livestock grazing, public recreation and the provisioning of clean water can be compatible goals.”

Roughly 1.8 million livestock graze on national forest lands in the western United States each year, the study said. In California, 500 active grazing allotments support 97,000 livestock across 8 million acres on 17 national forests.

“With an annual recreating population of over 26 million, California’s national forests are at the crossroad of a growing debate about the compatibility of livestock grazing with other activities dependent upon clean, safe water,” the study’s authors write.

“We often hear that livestock production isn’t compatible with environmental goals,” said principal investigator Kenneth Tate, a Cooperative Extension specialist in the UC Davis Department of Plant Sciences. “This helps to show that’s not absolutely true. There is no real evidence that we’re creating hot spots of human health risk with livestock grazing in these areas.”

For the complete article click on or copy and paste the link below into your web browser:


06-12-13 Marin Voice: Huffman’s four mistakes on oyster farm science

By Corey Goodman
Guest op-ed column

Posted:   06/12/2013 04:00:00 AM PDT

“Huffman’s district is ground zero for scientific misconduct.”

THE Sonoma City Council last week voted unanimously in support of Drakes Bay Oyster Co. and asked Rep. Jared Huffman, D-San Rafael, to support a bipartisan congressional investigation into the “questionable science” that misinformed Interior Secretary Salazar’s decision not to renew the farm’s permit.

Huffman immediately rejected the council’s request. In so doing, he made four substantive mistakes.

For the complete article click on or copy and paste the link below into your web browser:


05-20-2013 Dr. Goodman files rebuttal with DOI Jewell in response to EAC letter

Dr. Corey Filed filed a rebuttal today with Interior Secretary Jewell in response to a letter to the Secretary on May 16 from Environmental Action Committee of West Marin (EAC) Executive Director Amy Trainer.  In her letter to the Secretary, Amy Trainer misrepresented every report she cited.  This is not a case about a difference of opinions.  Rather, this is a case about the fabrication of facts and a cover-up.

These misrepresentations were intended to blunt a scientific misconduct complaint filed with Interior Secretary Jewell on May 13 alleging that both the National Park Service (NPS) and U.S. Geological Service (USGS) knowingly fabricated harbor seal data in their reports.  In the Final Environmental Impact Statement (FEIS), NPS claimed evidence of harbor seal disturbances by Drakes Bay Oyster Company (DBOC).

EAC continues to try to deceive the public and elected officials with misinformation.  It is difficult for our community to have an informed and thoughtful discussion when EAC continues to put out statements that they know are incorrect and misleading.

The so-called evidence of harbor seal disturbances by DBOC, as presented in the FEIS, was falsified.  NPS based its claim upon analysis by an independent harbor seal behavior expert, Dr. Brent Stewart of Hubbs-SeaWorld Research Institute.  But in contrast to what the NPS stated in the FEIS, Dr. Stewart twice found just the opposite, namely, no evidence of disturbances by DBOC skiffs.

For more on this, please click on the link below or copy and paste it into your web browser:


New Information Shows False Science Misinformed Interior Secretary Salazar for His Decision

Inverness, California, May 13, 2013 — A scientific misconduct complaint was filed today with Interior Secretary Jewell. This complaint was based in part on new information only made available this past week via both the Freedom of Information Act (FOIA) and from the independent scientist who did the harbor seal behavioral analysis for the National Park Service (NPS) and U.S. Geological Survey (USGS). The complaint, filed by Dr. Corey Goodman, concerns the NPS and USGS claim – shown to be false – that the independent scientist – Dr. Brent Stewart – found the oyster farm disturbed harbor seals at Drakes Estero, which he did not. The complaint alleges the public was deceived.

The new information shows that evidence of disturbances was falsified. This revelation has profound implications for Secretary Salazar’s decision to not renew the oyster farm permit, showing that USGS and NPS apparently misinformed Secretary Salazar using scientific claims they knew were incorrect, and that the Department of Justice continues to use the same false science to misinform the federal court.

For the full article, the scientific reports and all appendixes click on the link below or copy and paste it into your web browser:



In science, numbers often speak louder than words. Such is the case with data Jake de Grazia, a University of Southern California journalism student, and I collected concerning noise generated by the Drakes Bay Oyster Company (DBOC) skiff and oyster tumbler. (Jake is looking into the oyster controversy for his thesis.) In the Environmental Impact Statement (EIS) on the oyster farm, the National Park Service claimed that the skiff and tumbler are so noisy that they have a “major adverse impact,” disturbing harbor seals and visitor experience.

The (sound) data we gathered reveal that science has taken a backseat to ideology at Drakes Estero. They also have implications for the federal court case. While Interior declares to the public that the science doesn’t matter, that is not what federal lawyers are saying. In court, they are arguing that removing the oyster farm would be in the public interest because it could eliminate the major soundscape impact. As Jake and I confirmed, there are no data to support that claim.

To read the full text, click on the link below or copy and paste it into your web browser:


04-25-13 Red Herrings in Drakes Estero

“…there is nothing frivolous about our lawsuit, undertaken only after much deliberation and careful legal analysis by our pro bono legal team.  The anguish expressed during our pre-filing deliberations by Ms. Faber, whose own lifetime of laudable service to the cause of conservation in Marin rivals even Dr. Griffin’s, including her tireless efforts to bring about the Coastal Act and her service on the original CCC, was, for me, particularly sobering.

As made clear in our legal brief, the CCC has greatly exceeded its authority in this matter, working against its own statutory requirement to support coastal dependent activities, particularly aquaculture, and both replicating and exceeding authorities of the Fish and Game Commission, in direct violation of the Coastal Act.

With 14.5 million residents to feed in the SF Bay Area today, and 21 million projected by mid-century, the importance of this critical, sustainable, nearly perfect marine protein resource is increasingly obvious to all who care about the future of sustainable food production in our region.  DBOF is an archetypical example of exactly the type of food production we need more, not less of.  It is part of the solution to our growing dilemma; it is most certainly not part of the problem.

To read the full text, click on the link below or copy and paste it into your web browser:


“One of the saddest lessons of history is this: If we’ve been bamboozled long enough, we tend to reject any evidence of the Bamboozle. We’re no longer interested in finding out the truth. The Bamboozle has captured us. It is simply too painful to acknowledge―even to ourselves―that we’ve been so credulous.” ― Carl Sagan

03-11-13 Dr. Goodman’s Response to EAC’s complaint to White House Science Advisor

The Environmental Action Committee of West Marin (EAC), on March 6, 2013, submitted a letter to the White House Science Advisor, Dr. John Holdren (OSTP), objecting to Dr. Goodman’s recently submitted Scientific Misconduct Complaint.

Earlier today, Dr. Goodman submitted a comprehensive rebuttal to the EAC’s letter (submitted to OSTP by NPCA’s Neal Desai).

From the introduction to Dr. Goodman’s letter:

On March 4, 2013, I asked OSTP to establish and oversee a high-level investigation of scientific misconduct involving three federal agencies (NPS, USGS, and MMC), all linked to misconduct by NPS. I wrote that scientific misconduct emanating from NPS threatens to undermine one of the hallmarks of your tenure as OSTP Director: the establishment and implementation of President Obama’s Policy on Scientific Integrity.

My submission has come under attack by the Environmental Action Committee of West Marin (EAC) and others who do not share our view that the scientific method is core to the strength of our nation. Rather, they have an ideology and pre-determined agenda for which the ends justify the means. What we as scientists rely on as facts and data, they see as simply fungible inconveniences. If the real data get in the way, they can be changed as they wish. To them, data are a means to an end.

For NPS and their supporters, this is ideology, not science. Their goal is to get rid of the oyster farm from Drakes Estero by any means necessary. They are oblivious or are unconcerned that their false science also threatens the shellfish industry nationally and internationally, in contrast to a large body of good science showing that shellfish aquaculture is environmentally beneficial. Their agenda is to turn Drakes Estero into ‘wilderness’ – whatever the cost or collateral damage.

From the conclusion of Dr. Goodman’s letter:

This issue before OSTP is not about an oyster farm, and it is not about oysters or harbor seals. It is also, in contrast to what EAC wrote to you, neither about the Secretary’s decision, nor the Federal Court rulings. Rather, it is about whether we as a nation are truly committed to returning science to its rightful place in the federal government.

For the complete text of Dr. Goodman’s letter click the link below.


03-04-13 Email from Dr. Corey Goodman to White House Office of Science and Technology on Misconduct involving three agencies.

From: Corey Goodman <>

Subject: scientific misconduct submittal to OSTP

Date: March 4, 2013 8:05:48 AM PST

To: John Holdren <>

Dear Dr. Holdren,

I write to ask the White House Office of Science and Technology Policy (OSTP) to establish and oversee a high-level investigation of scientific misconduct involving three federal agencies (NPS, USGS, and MMC), all linked to misconduct by NPS.

To read the full letter and access accompanying documents, click on the link below or copy and paste it into your web browser:


03-02-2013 Russian River Times

“…the [Russian River] Times is left with two options to explain the IG’s failure to uncover any of the damning evidence found by the Times.  Either (1) the IG investigation is incompetent, and they merely took the NPS responses on their face with no proper investigation, or (2) the final IG report simply omits information that would be damaging to the NPS and the Department of the Interior, and that Interim IG Mary Kendall, as the committee implies, has essentially abandoned her watchdog responsibility.”

 “…the IG report will stand as just another in a long line of NPS and DOI investigations of themselves, costing the taxpayers literally millions of dollars, that are nothing more than whitewash and cover-up.”

To read the full article click on the link below or copy and paste it into your web browser:


01-23-13 Huffington Post

Sustainable Agriculture, Wilderness and DrakesBay Oysters: The Role of Science in Policy

Posted: 01/23/2013 6:47 pm, by Peter Gleick

In the past couple of years, a debate in Northern California over wilderness protection, sustainable agriculture, and the integrity of science has spiraled into the dirt. The fight is over whether to continue to permit a small privately managed oyster farm, the Drakes Bay Oyster Company, to continue to operate inside what is now the Point Reyes National Seashore in Marin County, California. The oyster operation predates the Park, having been in Drakes Estero for nearly a century, but the Estero is now eligible for wilderness status. Supporters of wilderness believe the oyster farm is an incompatible use and should be closed. Supporters of local sustainable agriculture believe the farm should remain because of its history, benign environmental impacts, and role in the local economy. In late 2012, after an extensive debate marked by disturbing scientific misconduct and abuse, local acrimony among long-time friends, and controversy among federal and state agencies, Interior Secretary Salazar ruled that the farm should be closed, giving the owners a mere 90 days to remove their operations, fire their employees, and abandon the farm.

Too often in the past few years bad science, or indeed a philosophy antithetical to science, has been pushed by special interests and some policymakers. This isn’t new — there is a long history of pseudoscientific or downright anti-scientific thinking and political culture — ironic, given how much founding fathers like Benjamin Franklin valued science.

Good science should have played a key role in the DrakesBay debacle, and open community discussion should have as well. But we didn’t get good science. Instead, the National Park Service, the Department of the Interior (DoI), and some local environmental supporters (with whom I often have strong common cause) manipulated, misreported and misrepresented science in their desire to support expanded wilderness. In an effort to produce a rationale to close the farm, false arguments were made that the farm damaged or disturbed local seagrasses, water quality, marine mammals and ecosystem diversity. These arguments have, one after another, been shown to be based on bad science and contradicted by evidence hidden or suppressed or ignored by federal agencies. The efforts of local scientists, especially Dr. Corey Goodman, professor emeritus from both Stanford and Berkeley and a member of the U.S. National Academy of Science, were central to revealing the extent of scientific misconduct. Reviews by independent scientists and now confirmed by investigations at the Department of Interior and the U.S. National Academy of Sciences show that arguments of environmental harm from the oyster farm were misleading and wrong. One of those reviews criticized the “willingness to allow subjective beliefs and values to guide scientific conclusions,” the use of “subjective conclusions, vague temporal and geographic references, and questionable mathematic calculations,” and “misconduct [that] arose from incomplete and biased evaluation and from blurring the line between exploration and advocacy through research.” The review by the National Academy of Sciences concluded that the Park Service:

selectively presented, over-interpreted, or misrepresented the available science on the potential impacts of the oyster mariculture operation.

In this case, I believe the decision to close the farm was the wrong one, done for the wrong reason, and it should be overturned. Supporters of the farm are still fighting, and it is possible that there will be a change of heart at either the federal level, or in the courts.

To read the full article click on the link below or copy and paste it into your web browser:


November 9, 2012

From:  Dr. Corey S. Goodman

To: Todd J. Zinser, Inspector General, Department of Commerce

“….In an article in the November 8, 2012 issue of the The West Marin Citizen (a local weekly newspaper in the West Marin community), entitled “Misconduct charged in Marine Mammal Commission report” and written by Lynn Axelrod, Mike Gosliner, General Counsel, MMC, is quoted from an exchange on November 7 as follows:

He (Gosliner) said ‘…. The allegations are probably not true or have a good alternative explanation.”’….

….Mr. Gosliner quoted from the 1990 Memorandum of Understanding between the MMC and the DOC OIG.

…. I quoted from the March 29, 2011 MMC Scientific Integrity Policy sent by Dr. Ragen to Dr. Holdren, Director, Office of Science and Technology Policy (OSTP), White House, in response to Dr. Holdren’s directive to all federal departments and agencies for such a policy.  Dr. Ragen’s 2011 letter to Dr. Holdren stated:

…., Mr. Gosliner should not be involved in this investigation.  He admitted that he had little time to read the complaint, but nevertheless told the press that the allegations are “probably not true.”  He also said that the complaint concerned scientific misconduct, when the complaint was filed primarily concerning “misconduct” and “deception.”  Much of the complaint involves the violation of laws, policies, guidelines, and regulations, and deceptive statements to the public and elected officials, and does not involve science per se (that is largely relegated to the appendix).

In conclusion, I stand by my complaint filed with you on November 7, and remain convinced that neither Executive Director Dr. Ragen, Chair Dr. Boness, or General Counsel Mr. Gosliner should be involved in any way in investigating these allegations.”

For the original letter, click the link below:

CSG to Zinser 11_09_12 response to MMC


10-04-2012: West Marin Citizen, Citizen’s Forum by Dr. Laura Watt: ” The nature of wilderness – past intentions for oyster farm’s future”

In my own research, reading through everything I’ve been able to find about the designation of wilderness at Point Reyes – the planning documents, comment letters from environmental organizations and members of the public, and testimony from Congressional hearings, as well as the formal bills and reports, and subsequent management plans – I have not come across any statements anticipating closure of the oyster farm in 2012.

In contrast, quite a number of statements suggest the opposite: that the oyster farm was intended to continue under potential wilderness designation, with no clear end point or expiration date. For instance, in the 1974 Final EIS for Proposed Wilderness (page 56), the NPS wrote, “This is the only oyster farm in the seashore. Control of the lease from the California Department of Fish and Game, with presumed renewal indefinitely, is within the rights reserved by the State on these submerged lands … and there is no foreseeable termination of this condition.”

By Laura Watt

Professor Laura Watt, Legislative and Administrative History Does Not Support NPS and Others Who Contend Oyster Farm to Close in 2012

for the Full article, click on the link below:


Information Quality Complaint to National Park Service | Cause of Action.

On August 7, 2012, a Data Quality Act Complaint was filed with the National Park Service by Dr. Corey Goodman and Kevin and Nancy Lunny, owners, Drakes Bay Oyster Company to make corrections as required by law and policy in the NPS Draft Environmental Impact Statement (DEIS) and the Atkins Final Peer Review (March 2012).
NPS must acknowledge the report within 10 days and by statute, respond within 60 days.

Summary of Complaint

To comply with applicable minimum information-quality standards, all scientific information that NPS disseminates in publications such as the DEIS and Atkins Peer Review Report must be, among other things, accurate and timely; based on the best available science and supporting studies and the most current information available; highly transparent; supported by reliable data, including on-site data when required by law; consistent with sound and accepted scientific practices and policies; evidence-based; reproducible by qualified third parties; and objective and unbiased in terms of both presentation and substance.

NPS can only claim that Alternative A is the “environmentally preferred alternative” because it flagrantly and repeatedly failed to comply with these minimum information-quality standards. Conclusions in the DEIS that DBOC causes “major” long-term adverse impacts on Drakes Estero’s “soundscape” and “wilderness” are based on inaccurate, nontransparent, false, and misleading data and analysis that violates NPS’s information-quality guidelines, as are claims that DBOC causes “moderate” long-term adverse impacts on Drakes Estero’s “harbor seals,” “birds and bird habitat,” and “visitor and recreation experience.”   If the DEIS is corrected to meet basic minimum information-quality standards, it becomes clear that DBOC’s operations do not have long-term adverse impacts on Drakes Estero’s environment.

Click on the link above or copy and paste this link into your web browser


russianrivertimes | Just another site.

“We cannot overemphasize how damaging NPS

behavior has been to the local public’s perception of

federal science and policy, not only regarding

the oyster farm, but a host of other issues. 

NPS and its consultants are asking us to believe that a

300-fold error in sound footprint, as shown in the previous graphic,

makes no difference to the conclusions of the EIS. 

This is clearly stated in a May 7, 2012 letter from 

peer review consultant ATKINS to Dr. Ralph Morgenweck. DOI Scientific Integrity Officer.  

Essentially, having been caught with their hand in the data jar,

the NPS consultant abdicates responsibility by saying that the EIS is fine, no one is wrong,

it’s too complicated and that tired, over-used scientific excuse, ‘further research is required’. 

It never addresses the huge errors caused by the bogus NPS data nor its origin.

The citizens of West Marin and the general public know when they are being lied to

by NPS and its consultants.  We look to your panel to protect us from this kind of

scientific dishonesty and abuse of policy.”

For the full article, please click on the link above.

06-07-2012 Dr. Goodman regarding Photographic Evidence of Sound Deception in the dEIS.

“A government photograph taken during the course of a 2010 Federal Aviation Administration (FAA) acoustic study at Point Reyes shows an unobstructed view from an FAA microphone along theshore ofDrakes Esteroto a Drakes Bay Oyster Company (DBOC) oyster boat. Th[e] photo—recently obtained from government sources outside the National Park Service (NPS)—provides key evidence that the NPS deceived the public and concealed key data in their Draft Environmental Impact Statement (DEIS) on DBOC. Understanding the important of this photo—and how it contradicts the DEIS—requires some context.”

To read the entire article, click the link below:

04-24-12 World renowned scientist and elected member of the National Academy of Sciences, Dr. Corey S. Goodman,

sent a letter to DOI Acting IG Kendall, DOI Science Integrity Officer Morgenweck, and NPS Science Integrity Officer Machlis regarding :

“Allegations of false representations of data, concealment of data, and deception involving unnamed NPS and VHB employees who wrote, revised, and reviewed the NPS DEIS on Drakes Estero.”

Dr. Goodman is asking the Department of the Interior

to assure the public that:

  • NPS will publicly withdraw their DEIS on Drakes Estero
  • ATKINS will publicly withdraw their peer-review report; and
  • Interior and NPS will cancel the Vanasse Hangen Brustlin contract”
[In that they]
1. Failed to follow NPS Management Policies 2006 and Director’s Order #47
2. Made false representations of key acoustic data in Chapter 3 of the DEIS
3. Made false representations of key acoustic data in Chapter 4 of the DEIS
4. Concealed key acoustic data in Chapters 3 and 4 that contradicted DEIS
5. Drove incorrect findings of major impacts in Chapter 2 of the DEIS
6. Knowingly deceived the public and peer-reviewers in the DEIS.
The word ‘deception’ is not found in the Interior Scientific Integrity Policy. It is not part of the definition of scientific misconduct. Rather, it is part of the definition of FRAUD.” Dr. Goodman explained. (emphasis added is mine).
He further stated, “The bias – and willingness – to misuse science for a predetermined agenda is pervasive in this DEIS, a document that was seen, touched, and influenced by many people at NPS. This bias also represents a cultural problem that starts with top leaders and managers and spreads throughout the organization. It represents a crisis of leadership.”“…No one employee is responsible for this problem. It involves many people. It is time to look into the soul of the Park Service and ask how to fix this systemic problem so that it never happens again, so that science is returned to its rightful place, and so that NPS employees can be proud of the tremendous work they do to protect our special lands. ”
For the full text of the letter, click the link below:
For the six part Power Point Presentation accompanying the letter follows:

NPS DEIS soundscape deception executive summary

NPS DEIS soundscape deception.part 1

NPS DEIS soundscape deception.part 2

NPS DEIS soundscape deception.part 3

NPS DEIS soundscape deception.part 4

NPS DEIS soundscape deception.part 5

NPS DEIS soundscape deception.part 6

NPS DEIS soundscape deception EPILOGUE


03-26-12 World renowned and elected member of the National Academy of Sciences, Dr. Corey Goodman summarization of NPS Deception & Falsification of Scientific Data

“Both NPS and VHB employees were involved in writing, revising, or reviewing the soundscape section…. in the revisions … between the June 2011 non-public version … and the September 2011 public version of the DEIS. The legend and labeling of Table 3-3 were intentionally revised so as to deceive the public. Key words were changed; descriptions of the sources for sound estimates deleted.”

For the full text of Dr. Goodman’s summary

summary of NPS DEIS and ATKINS review soundscape deception


03-26-12 NPS used falsified acoustic data to deceive the Public and a Peer Review of the dEIS

This is a large file and may take extra time to open.

NPS DEIS and ATKINS review soundscape deception.9.2MB


03-26-12 Falsified Data in dEIS and Peer Review

CSG to Salazar.03_26_12


03-01-12 Atkins Review



12-09-11 Actual study of Drakes Bay Oyster Company Boats and equipment reveals the deception in the dEIS of the NPS.

“ENVIRON International Corporation (ENVIRON) has reviewed the Draft Environmental Impact Statement (DEIS) Drakes Bay Oyster Company Special Use Permit (ID: 43390), and appreciates this opportunity to report our technical comments to the National Park Service (NPS) in print form. ENVIRON regularly participates in NEPA processes such as this, and respects the effort put forth by the NPS in order to develop this draft document. The purpose of these comments is to assist the NPS in developing a more scientifically accurate and complete final document that is consistent with NEPA and NPS policy.

In general, the structure of the DEIS is unusual in that there is no alternative that represents the proposed action. Neither is there an alternative that represents a continuation of current conditions. In the current structure of the DEIS, the public is left to glean unknown conditions without the Drakes Bay Oyster Company (DBOC) as the no action scenario. Consequently, the impacts resulting from conditions under alternatives that depart from this unknown status (Alternative A) are even more difficult to understand. No explanation is provided for this deviation from standard NEPA protocol, and ENVIRON questions the efficacy of this approach. Setting aside the DEIS structure, comments have been developed in several topic areas.
ENVIRON found consistent omissions and mistakes that err in a way that exaggerates potential negative impacts and understates potential positive impacts benefits. NEPA protocol requires the author to apply a net impact analysis – an assessment of both positive and negative impacts. Without this net approach, results could point toward a ‘least negative’ alternative which might in fact be worse for the environment than another option that had more negatives, but more positives that potentially balance out or mitigate for the negative impacts.”

For the full text of the report click the link below:



11/22/2011 Analysis of MMC Report by Dr. Corey Goodman

Briefly, the following three points, as stated by Dr. Corey Goodman, sum up the MMC report.

1. The NPS data are too thin, and too highly leveraged by a stochastic event in 2003, to be able to support the NPS correlation between harbor seals and oyster activity. Moreover, the NPS data are inadequate for MMC to affirm the NPS claim of a correlation between harbor seals and oyster activity.

2. What was called a long-term displacement OUT of Drakes Estero was actually a short-term displacement INTO Drakes Estero caused by events at Double Point. There is no evidence for long-term spatial displacement of seals and pups OUT of Drakes Estero that can be related to shellfish aquaculture.

3. The MMC mistakes could have been avoided had the MMC proceeded with their original open process rather than the insular closed process they conducted. Open dialogue, open discussion, and open exchange could have helped avoid these mistakes. Unfortunately, the closed process led to a flawed MMC Report.

For the Summary of MMC I and MMC II, click here:

Summary of Analysis of MMC Reports I and II.CG&DL

For the Analysis of MMC Report I, click here:

Analysis of MMC Report I. acceptance of NPS correlation.CG&DL

For the Analysis of MMC Report II, click here:

Analysis of MMC Report II. rejection of Goodman.pdf models.CG&DL


11-22-2011 MMC Drakes Estero Report Mariculture and Harbor Seals in Drakes Estero, California

We recommend you read Appendix F prior to reading the full report which can be summed up by their statement on page iii of the Executive Summary excerpted here:

“The Marine Mammal Commission believes that the data supporting the … analyses are scant and have been stretched to their limit. Nevertheless, the analyses in Becker et al. (2011) provide some support for the conclusion that harbor seal habitat-use patterns and mariculture activities in Drakes Estero are at least correlated. However, the data and analyses are not sufficient to demonstrate a causal relationship.

For Appendix F, click the link below:


For the complete report, click the link below:



10/28/2011 Dr. Peter Gleick  article in Huffington Post: Bad Science Leads to Bad Policy

“…the National Park Service, the Department of the Interior (DOI), and some local environmental supporters (with whom I usually have strong common cause) have manipulated science in their efforts to close the farm. A series of reports have been issued with bad, incomplete, misleading, or cherry-picked evidence of impacts to seagrasses, water quality, fish diversity, and especially seals.”


10/27/2011 Dr. Gleick and Dr. Raymond Defend Dr. Goodman

regarding “…inexcusable defense of bad science by the National Park Service by a small number of loud players with vested interests  In particular, we decry the recent barrage of letter after letter published in the West Marin Citizen filled with personal attacks on the integrity of a highly respected scientist, Dr. Corey Goodman. Dr. Goodman, at huge personal cost to his time and reputation, has been in the front lines of efforts to ensure that the National Park Service’s blatant disregard for scientific integrity does not go unchallenged. His efforts, partly at the request of  County Supervisor Steve Kinsey, have exposed serious and serial bad science.”


10-16-2011, Dr. Corey Goodman gave a presentation to the community about the science behind the Environmental Impact Statement.

The National Park Service was invited to share the podium with Dr. Goodman for an open discussion of the science behind the draft EIS followed by a Q&A with the audience. Three days before the event the NPS declined the invitation and suggested the public attend their “open house” meetings instead to follow later that week. 150 attendees were treated to an hour and a half presentation of the science followed by over two hours of Q&A.  A video of Dr. Goodman’s October 16, 2011 talk at the Dance Palace on his analysis of the science behind the draft EIS and the Becker 2011 paper have been posted.


02-2011 Vol 61 #2 BioScience: Oysters identified as Threatened or Imperiled Species

… oyster reefs once dominated many estuaries… ecologically and economically… oyster reefs [are at] the brink of functional extinction worldwide….

Oysters have been identified as a threatened or imperiled species and as a threatened and declining habitat by a number of countries in Northern Europe, around the Black Sea, in the United Kingdom, and elsewhere….  Similar listings are appropriate in many regions and countries, including in the United States….

  • Oyster reefs and beds were once a dominant  structural  and  ecological  component  of estuaries around the globe, fueling coastal economies for centuries.
  • Oysters are ecosystem engineers;… produc[ing] reef habitat for entire ecosystems…
  • [Oysters] have supported civilizations for millenia, from Romans to California railroad workers….
  • In 1864, 700 million European flat oysters… were consumed in London, and nearly 120,000 workers were employed as oyster dredgers in Britain.
  • Shell piles from historical harvests in the southwest of France contain more than 1 trillion shells apiece, underscoring both the productivity of the species and the scale of harvest ….
  • In the 1870s, intertidal reefs of the eastern oyster  extended for miles along the main axis of the James River in the Chesapeake Bay; by the 1940s, these reefs had largely disappeared ….
  • In many coastal areas, including the Texas coast, roads were paved with oyster shells….
  • Oyster reefs are one of the few marine ecosystems for which direct estimates of condition can be calculated

For more on this as well as a link to the original article, click on or copy and paste the link below into your web browser:


July/August 2009 Russian River Times, John Hulls

A river of environmental misinformation flows all the way from a card table in Sebastopol, across the country, down C Street in Washington, past the Department of Interior, and eventually discharges into the halls of Congress.  The Russian River Times tracked it to its source.

A few days ago, at a table outside the Sebastopol Whole Foods store, a representative of a local environmental coalition was asking patrons to sign a petition.  It asked Rep. Lynn Woolsey to reverse her support of Senator Feinstein’s proposed legislation to extend the lease of a historic oyster farm, located on Drake’s Estero within Point Reyes National Seashore.  According to the petition handout, it was being presented by Save Drakes Bay (SDB), a coalition of environmental groups, including amongst others, the Sierra Club, the National Parks Conservation Association and the Environmental Action Committee of West Marin.

The person at the table, who identified himself as ‘Brian’ showed an aerial photo of eel grass beds, pointing out that eelgrass, an important part of the ecosystem, was “nearly all gone” and that the shaded areas showed where it was “dying because of the oysters”. He claimed that the “seals were dying” as the result of the “oyster factory operation”.  He claimed that if Feinstein’s amendment to the Park Service appropriations bill were approved, it would “destroy the Wilderness Act” for the commercial benefit of a local business owner.

None of these charges are true.

A recent report by the National Academy of Sciences, commissioned by the National Park Service at the request of Senator Feinstein, shows that there is no scientific indication that Drakes Bay Oyster Company (DBOC) is having any meaningful negative effects on the Estero

To read more, click on the link below or copy and paste it into your web browser:


2009 Monterey Bay Aquarium Report “Turning the Tide, The State of Seafood”

creates the ‘Super Green List, with oysters  third on the list of eight seafoods, behind only Albacore Tuna and Mussels. Also found in this report is “Several kinds of shellfish aquaculture are recognized as environmentally responsible, including the farming of bivalves like clams, oysters, mussels and scallops….farming shellfish has few negative impacts overall….incresed abundance of shellfish in an area is often considered to have a positive effect on water quality….”

Monterey Bay Aquarium Report on The State of Seafood 2009


01-18-09 Dr. Corey Goodman letter to Dr. Susan Roberts, director, Dr. Pete Peterson, Chair, and members, Ocean Studies Board panel 

RE:  New Information Shows that the National Park Service Committed Scientific Misconduct in the Documents it Presented

“…all of the ‘mariculture-related’ disturbances in 2007 cited by the NPS occurred in less than two weeks prior to the May 8, 2007 Marin County Board of Supervisors hearing.

Tide charts and direct experimental analysis … reveal the sandbars in question were under water when seals were supposedly observed getting flushed into the water….by oyster workers that time clock and payroll records show were not working.”

For the text of the entire report, click the link below.

Dr Goodman to NAS 01-18-09


12-18-07 Dr. Corey Goodman letter to Dr. Susan Roberts, Ocean Studies Board, National Research Council, National Academy of Sciences 

RE:  Violations of Federal Policy on Research, THE CASE FOR SCIENTIFIC MISCONDUCT; The attempt to Cover-up the NPS Misconduct and Prevent its Investigation by Jon Jarvis, and David Graber; and the Failure to Properly Investigate Misconduct in Objective and Timely Fashion by the DOI’s Office including Attorney Molly Ross.”

Dr Goodman to NAS 12-18-07


Dr. Sarah Allen testifies in a 2005 lawsuit in San Diego (Children’s Pool Beach Case). Court decision: Dr. Sarah Allen testified that seals habituate (or anthropomorphizing) to disturbance sources that are determined not to be a threat.”

Dr. Sarah Allen concluded seals habituate to disturbances they determine not to be a threat after a 7 year 4 month study titled “Monitoring the Potential Impact of the Seismic Retrofit Construction Activities at the Richmond San Rafael Bridge on Harbor Seals…” in which “Construction-related disturbances,,,were attributed to … watercraft … and construction activities such as jack-hammering, rivet work, hammering and the movement of cranes on barges near [within 20 yards of] the haul-out site.” In contrast, DBOC boats are 750 yards away from harbor seal haul-out site.  

7 Year Harbor Seal study by Dr Sarah Allen 2005


2005 Dr. Sarah Allen’s Harbor Seal Monitoring at Point Reyes National Seashore and Golden Gate National Recreation Area Annual Report 2005

finds “Causes for disturbance at Drakes Estero … birds most frequent cause, followed by non-motor boats [kayakers], humans [hikers], aircraft.” in conclusion she finds “The number of disturbances … remains similar to previous years and no trends are detected….hikers and boaters remain the two most frequent sources of disturbance ….”

Harbor Seal Report 2005


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