K.N.I. Bell, B.Sc., M.Sc. (Dalhousie), Ph.D. (Memorial)

Visiting Scientist

Home (Canada):

J.L.B. Smith Inst. Ichthyology

25 Monkstown Rd.

Private Bag 1015

St. John's, Nfld

Grahamstown, 6140 SOUTH AFRICA

Canada a1c 3t2

Ph: +27 046 636 1002, FAX: 046 622 2403,

E-mail: <ihkb@giraffe.ru.ac.za>


April 10, 1998

TO:    All COSEWIC members [if you are aware of any member not receiving this message, please if possible forward the message to that person and notify the sender]

Re: Unexpurgated version of Cod Report

Dear Committee Member:

Enclosed (electronically) with this message is the current version of the Cod Report that has the author's approval. The Report that you received from COSEWIC was extensively altered within COSEWIC, without seeking the author's approval. Some of the changes may have been made with good intention. But the number of changes, and their possible effect, is simply too great to ignore.

By all means recognise that the statements in it are not necessarily those of COSEWIC; but this leaves you in less doubt than the version sent from the SC Chair, in which version the reader without the original cannot know whose opinion any given statement might accurately reflect.

The changes within the Report were mentioned neither in the cover letter to members (Feb 19, which mentioned only the amputation of the Addendum, not copied to the author until requested), nor in the Errata message (Mar 9, which mentioned typos but didn't mention the far more serious issue of altered meanings, although this problem had been clearly noted to COSEWIC). It is not even clearly stated that those typos originated with the COSEWIC edit (as opposed to the Author's or anyone else's edit).

While the SC Chair's cover letter to members mentioned the amputation of the Addendum but not the other alterations, the letter to the author (Feb 19) did not mention the Addendum at all but merely referred to "some editing". Thus, there was an odd complementarity to the incomplete information supplied to the author and the members.

The SC Chair sent (letter Feb19), after the fact only, merely the following allusion to the alterations: "Some editing of the report was undertaken to bring the style and format into line with all other reports and to ensure there were no politically sensitive comments which could lead to outright rejection of the report. The changes have not been substantial and do not alter the content of the report. "

Key points are:

(1) The idea of suppression of statements based on the notion of "politically sensitive", where there is relevance to the question at hand, is repugnant in a democracy and anathema to the principle of full discussion of a scientific issue.

(2) Without regard to the question of validity of those reasons, it is grossly improper to make alterations with neither approval nor an attempt to obtain approval.

(3) "Some editing" suggests few and minor changes only, as does the SC Chair's assurance "the changes have not been substantial and do not alter the content of the report". But does this accurately convey the kind and abundance of alterations? Summary comparisons show:

CUTS: But removal of the Addendum (not listed in the Feb. 19 letter to me, but confirmed only after explicit questions) alone is a removal of 10,776 words in 182 paragraphs. Further extensive amounts were cut from the body of the Report: 6,020 words and 120 paragraphs. Many of these cuts affected text that existed at the previous meeting, but no request had been received from the SC Chair to suggest that these particular cuts (or any) should be made; what changed to put those sections on the cut list?

ALTERATIONS: Just in the first 23 pages of the Report alone, there are approximately 170 changes. These include: altered (softened) statements; quotes removed so that other's words appear to originate with (and erroneously appear to have support of) the Report; an altered figure reference (figure referred to cannot be located); altered bibliographic citations (some citations are now untraceable); removal of actual discussions of similar situations elsewhere (it was part of the original request that Europe be considered so the cut is inexplicable); removal of discussion of problems in the sections under the COSEWIC standard outline heading 'Protection' (parts cut included those that were praised by COSEWIC's independent reviewers, and those parts had been present for several versions without requests for removal from the SC Chair).

"Some editing" is a vast understatement.

Even in terms of the dubious motivations offered (format, political), many changes and softenings remain inexplicable. How can the following examples be justified in terms of format or political sensitivity, given that they all alter meaning?

"there are few indications of improvement" TO "there are indications of improvement";

"re-opening, these recommendations are explicitly contradicted by" TO "re-opening, these recommendations appear to be contradicted by";

"above; there is virtually no doubt that overfishing is the sufficient and major cause of these declines" TO "above; overfishing appers [sic] to be a sufficient and major cause of these declines";

"There is no doubt that overfishing has occurred" TO "There is no doubt that to come [sic] extent overfishing has occurred";

"The existence of biologically meaningful stocks must be accepted by COSEWIC" TO "The existence of biologically meaningful stocks may thus be accepted by COSEWIC";

"If a single designation is insisted on, it must be the same that would apply to the most at-risk stock/population/component" TO (deleted entirely) ...

The tone of the document is significantly altered by massive deletions, change to tentative wording, and by removal of quote marks and rewording of quotations such as to make them seem to originate with the Report (and to seem thus to be un-contested). Some citations were mixed up, some statements became referenced to the wrong source, some citations lost their correspondence with the bibliography, and one figure became mis-referenced. A few lines on the cover, listing the main changes[[*]] for the convenience of the reader, was deleted. Even the author's e-mail address was deleted. Adjectives that could apply to the altered version are: censored, expurgated, altered, disrupted, mutated, sanitised, tenderised.    [[*meaning in context: author's changes since previously presented version (note added 20050707)]]

To send out a report under an author's name, with unapproved changes, without notification of the extent of alterations, is misrepresentation. The reason offered for lack of notice is the rush to get the Report out (the SC Chair correctly noted in his cover letter to you Feb 19 that the lateness of critical DFO documents put the schedule out), but there is no reason that the author couldn't have been asked to approve this process and neither is there a reason the author couldn't have at least been notified. There is also no reason that a disclaimer could not have been attached, instead of altering the Report. Indeed, COSEWIC did insert a disclaimer in one section of the Report, yet went ahead with editing elsewhere. What is missing is the equivalent disclaimer that the altered statements do not necessarily or accurately reflect the views of the author. The only question remaining is: whose views do the altered statements represent?

COSEWIC Procedure, independence, & objective decision-making

Much of what was removed from the Report by COSEWIC was material that addressed the written comments of DFO.

The Addendum, which dealt predominantly with the DFO objections to this Report, was cut entirely. This, and the cutting and alteration in the main body of the Report, presumably reflects the "politically sensitive" aspect offered as a motivation for removal. Given that the Addendum addressed arguments formally presented to COSEWIC and forwarded to the author for consideration, removal of rebuttals on this basis is untenable. Given that many of DFO's own quoted statements were cut, it should be perplexing.

The very idea of suppression of statements based on the notion of "politically sensitive" is anathema to the principle of full discussion of a scientific issue. It certainly is inconsistent with claims that COSEWIC enjoys a free discussion on a purely scientific basis, of each issue. (Ironically, COSEWIC's position, if this is its position, that some things about Cod and the surrounding circumstances not only are "politically sensitive" but can be suppressed even in the context of a scientific question, is itself a political statement and counter to much of the protestation by DFO that government politics do not interfere with science. Perhaps COSEWIC's position makes it official: Cod is Political.)

COSEWIC is the only National venue for the arbitration of potentially difficult questions that are important for the recognition of species' conservation status. A reasonable supposition is that COSEWIC wishes to be, and be seen as, credible. For this it needs to be open, comprehensive, objective, and for the latter it needs to be procedurally balanced.

A balanced process requires that any comment concerning a Report and proffered for acceptance must be equally available for rebuttal. If some comments sent to authors or uttered publicly are to be considered for acceptance but not rebuttal, the process is unbalanced. If something is considered too "pointed" or "politically sensitive", the author could be asked to re-phrase, as long as this does not exclude proper rebuttals to a particular point. The need for free rebuttal and debate must prevail over the wish for a certain tone. If a stricture is applied to rebuttals it should apply also in criticisms.

It is standard in science to have disagreements resolved by subjecting all claims to rigorous analysis, but there seems to be no way for this to occur within COSEWIC procedures as illustrated by the censoring of the Cod Report. If rebuttal of inane, absurd, or factually incorrect objections are labelled 'politically sensitive' and excised, then any inane, absurd, or factually incorrect objection stands effectively unchallenged. But is it acceptable for COSEWIC to make its decisions on the basis of unchallenged, inane, absurd, or factually incorrect assertions? Surely not, because this would be at odds with COSEWIC claims that decisions are made on an objective and scientific basis.

Therefore, COSEWIC needs, but seems to lack, a formal means for rebuttal of incorrect assertions of fact and invalid criticisms. Contentious issues need to be dealt with and retired so that they do not re-emerge to subvert final discussions at the designation meeting.

One of two reviews is required: either of the administration of COSEWIC's procedures, or of the procedures themselves.

The time for considering and making changes is after discussion, after a designation, and after the Author's approval of the requested changes. Not before.


K.N.I. Bell

attached. Cod Report, author's version up to date.