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The illegitimate consultations |
Quiz of the day: What famous
person said:
“You understand that
when someone says they’re waiting for “all the facts” before they
make a choice, they’re actually just avoiding a decision and hoping
it will go away”
[answer below]
Lurking in a feelgood speech by the Hon. David Anderson March 03 2004 ...
... was the first inkling
of a cynical end-run around the publicly claimed purposes of SARA (Species
at Risk Act). The consultations are illegitimate. Why? Because
they were outside SARA, and they attempt to defeat the stated objectives
of SARA. They are also wastefully duplicative of the 3 rounds of
better-informed
consultations already provided for by SARA. |
Correspondence re SARA and Listings: the illegitimate consultations of 2004 1: Letter May 14 2004 to SARA. Response to first announcement by Anderson. 2: Letter Nov 17 to DFO consultations. 3: Bell 2004: "Special
designation would protect Cod". Telegram Forum, St. John's
Evening Telegram, Nov. 06 2004 p A11.
|
|
Because there is no proposed plan, there's no way to know about "costs and benefits". That means these consultations ask for an un-informed opinion. That's senseless. These extra-SARA consultations are purely political and they are an enormous waste of time and money. The correspondence and articles show why
the Listings should be made, why SARA should be amended to provide for
automatic acceptance of fact, i.e. acceptance of what it says is the
best scientific advice on the question, and why SARA should separate fact and action. The current illegitimate consultations are an obvious ploy to give government an excuse for not Listing species whose protection is irksome. Everybody knows Bell is no
pal of COSEWIC; so why does he strongly urge a Listing? |
With a red cape, you can make a bull
go anywhere.
The DFO "SARA" consultations
came with an information poster with white print on a black banner at the top:
Species
at Risk Act Public Consultations
October and November 2004 |
(top of DFO poster, their filename "Species-at-Risk-(E&F).pdf"), but it is a lie! ... they are not "Species at Risk Act Public Consultations", they are not provided for by "SARA", and SARA provides for other, better, consultations (see above).
Where does it say to send your comments to? Superficially, it looks like you are writing to SARA:
what it says: |
but look what it omits: |
" saracomments@dfo-mpo.gc.ca
• Writing to: Species at Risk Office P O Box 5667 St. John’s, NL A1C 5X1 " |
<-- "Species at Risk Office" isn't SARA, yet it doesn't say 'DFO'. <-- that's DFO's address. <-- SARA has no St. John's office. |
Look at that address: it looks like it could belong to SARA, and clearly
meant to; but no, it's a DFO address.
There's even a section "Who can I contact for more information about
SARA?" and for Cosewic, with SARA and Cosewic addresses. The presence of
those addresses tends to support the illusion that these are "SARA" consultations,
although they are not.
The way the poster is set up, it's easy to miss the fact that
DFO set up the consultations. In
fact
a
common
complaint
was
that
there
were no
SARA or COSEWIC people there. But they were DFO's hearings!
The Cosewic Chair (Marco Festa-Bianchet)
gave a talk at MUN in April 2005. He moaned that COSEWIC was taking all the
flak for this, the bulk of the objections
to
Listing
seemed to point at Cosewic.
(Shoulda
thought
of
that before playing ball, but he's an academic (U. Sherbrooke)). Cosewic is
tactically so outclassed by DFO, you'd think the smart thing would be to catch
on. You'd think he'd maybe counter the flak by pointing
out exactly how deeply DFO was involved in the Assessment; but ... ummm ...
that'd mean admitting
he'd played
ball too. Outclassed.
Speaking of tactics, a DFO person the other
day (June 2005) griped about no SARA people or COSEWIC people being
at the DFO consultations. (Though that probably worked for DFO too.) My simple
reply was "of course not: not invited, not part of the plan".
He couldn't remember how the consultations had been arranged to point the
objections at SARA and COSEWIC, but he didn't deny that it had worked out
well for DFO (when
you're the one that mismanaged the fishery, it's quite a feat to get all
the fishermen to do what you want by getting them angry with SARA and COSEWIC).
To argue against it having been engineered he offered the defence that DFO
wasn't
nearly smart enough to engineer all this stuff. I can see the headline: "DFO
staffer advances 'stupid but lucky' hypothesis".
(Quiz answer: the quoted famous person is ... Hon. David Anderson, March 5, 2004) [http://www.ec.gc.ca/minister/speeches/2004/040305_s_e.htm] |
BACKGROUND ITEMS: 1997-8 Report: Status of Atlantic Cod
(for COSEWIC)
of which the 2003
Report is an Update
COSEWIC does not want anyone to see* the 1998 Report "Status of Atlantic Cod in Canada", so it is provided here as separate html files of Report text and Report figures. (*Even the author of the 2003 Update Report says they didn't give him a copy, and says that's why, unlike other Update Reports, it does not mention the previous one.)
This is the Report as submitted, which is distinct from the version that COSEWIC changed without permission, not the faked version they tried to make me agree to, or the whitewash they later tried to say I was asked for.PRESS coverage of the 97-8 Report. See especially the Ottawa Citizen front-page article that preceded the 98 meeting; without that, Cosewic would probably have once more deferred the issue, as it did in 97 on a politically trumped-up procedural basis, or prevented an at-risk designation.
Note that the 97-8 Report made its Recommendation on the basis of 10 management areas, acknowledging that these already were too large and redefinition of populations should be supported and incorporated. Note that DFO (W. Doubleday, letter to COSEWIC) itself had previously and vehemently demanded a multiple-areas treatment, and I agreed. DFO abruptly changed its mind. COSEWIC asked for no explanation of why DFO would change its mind, and accommodated DFO's revised wish for a single-unit assessment (which even COSEWIC says, in the 2003 Update, could not be a correct decision under the information available) and yet their Chair says (2004) there were no "other inputs" in 1998 besides the Report. Clearly that means no other inputs they want to declare, and that is what they'd have to do if they released the Report, so their reason for not releasing it is also clear.
Note that in the 2003 Update, they still did not address it at the finest scale possible, but kept it to 3 major areas (plus Arctic). Under COSEWIC's practise of modifying Reports to fit their decisions, it is not yet known whether the "3 areas" solution was imposed on the author of the 2003 Report, or whether he accepted it easily. Either way, any Report from COSEWIC is not guaranteed to be what SARA says it must be, i.e. the Report on which COSEWIC's decision (assessment) was based (if you changed it, it isn't what it was when you used it as input). Thus, we have to conclude that all COSEWIC assessments and released Reports are biased in the 'don't -list' direction.
A key section in the Addendum* is DFO's shifting position on populations ... it shows the origin of DFO's one-population tactic to minimise seriousness of any Listing, the same tactic that's key to generating red-herring fears (of horrendous fines, any fishery closed down if there's bycatch). Of course, those fears are intended to generate political opposition to a Listing.
(*Why an Addendum? COSEWIC's procedures were not scientific, did not allow for differences to be debated, did not require a Jurisdiction (e.g. DFO) to substantiate its objections, and allowed DFO to abruptly and without explanation change its mind on the key issue of whether Cod should be treated as 1 or many populations. In other words, Cosewic has no system for scrutiny of Jurisdictions' or Members' arguments, it is quite one-sided, and Jurisdictions/Members are therefore not held accountable for their comments by Cosewic. An Addendum was the only way to make the Jursidiction (DFO) accountable for its own statements that were in bad faith, i.e. designed more to frustrate the process than contribute to it.)