Tuesday, August 4, 2009

The Double Standard: RSG v. SAT

Philip Beguhl

P.O. Box 6886

Santa Barbara. CA 93160


Commercial Fishing Representative

Santa Barbara County Fish & Game Commission – 26 years

M.L.P.A. - S.C.R.S.G. member

Commercial Fisherman - 40 Years


July 31, 2009



The Double Standard


The MLPA team has structured the R.S.G. decision-making process to give the position held (work product) by the minority of stakeholders the same opportunity to go forward and be used and evaluated by the B.R.T.F. and possibly the F&G Commission as the majority. This under the rationale that the majority position of the R.S.G. is an artifact of the current personnel make-up of the R.S.G. and a different set of R.S.G. members would have a different M.P.A. design result. Therefore to be fair and transparent the minority position of the R.S.G. is given equal footing with the majority.


To avoid a significant double standard that will inject profound bias into the M.L.P.A. process. It is imperative that the same standard be applied to the work product (S.A.T. guidelines) of the S.A.T.


As the personnel make-up of the S.A.T. also causes their work product to be in part an artifact of their particular perspectives. It is obvious the empanelling of a different group of scientists has the potential to produce a much different result. It is necessary in the name of process fairness, transparency and scientific integrity that at the very least a "safe harbor" is established on the S.A.T. and a "minority opinion" set of S.A.T. guidelines is so generated. And that these guidelines be given full consideration by the R.S.G. B.R.T.F. and ultimately by the F&G Commission.


Obviously having two sets of S.A.T. guidelines would complicate the M.L.P.A. process but to be scientifically correct the production of a majority and minority position on such key metrics as size and spacing and L.O.P. is the only practical and "consistent standard" way to deal with the bias introduced by the vagrancies of R.S.G. and S.A.T. personnel configurations.


No one said this would be simple or fast. If you want simple and fast then let the R.S.G. vote with majority rule consistent with the way the S.A.T. votes. If you want fairness and transparency, you will slow down and let the minority position of the S.A.T. go forward in this process. One standard of fairness or the other - not two!!

There is no substantive difference between the R.S.G. and the S.A.T. to justify the double standard currently in place.


The M.L.P.A. initiative as a whole must rectify this double standard before we move forward.


Sincerely,



Philip Beguhl



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