Submission to Senate Inquiry
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Submission to Senate Inquiry “The identification of leading practices in ensuring evidence-based regulation of farm practices that impact water quality outcomes in the Great Barrier Reef” Dr. Lachlan Stewart Lachlan Stewart (PhD) is the Principal of Science Audit Service, a consultancy providing advice on the strengths or shortcomings of published scientific work. He holds the following tertiary qualifications: BSc (Mathematics), Class 1 Honours (Earth Science) and PhD (Earth Science), and his contributions to science have been recognised by the inclusion of his biography in Marquis Who’s Who in the World. Most of his career has been spent in the employment of James Cook University (JCU) and the CSIRO. He has held various paid research roles at JCU within the then departments of Physics (Radar Oceanography), Mathematics (Spinor and Tensor research software), Earth Sciences (Cooperative Research Centre Task 1.3.1/2 Sediment Accumulation and Dynamics on the Great Barrier Reef (GBR)), and Civil and Systems Engineering (Crown of Thorn Starfish dispersal modelling) and this experience has given him a very broad base of scientific understanding. Within the CSIRO he was heavily involved in the modelling and monitoring of sediment and nutrient delivery to the GBR lagoon from the Tully and Murray River catchments in North Queensland. In addition, he was also involved in the modelling of sugarcane crop growth and nitrate delivery to ground water under sugarcane cropping in the Burdekin delta. He is an author on 18 scientific papers published in international and national science research journals and numerous reports. Executive Summary Science Quality Assurance Based on my experience in auditing Great Barrier Reef (GBR) related science it is my opinion that there is a marked problem with the standard of quality assurance provided by the peer review process. I have conducted partial audits of two Great Barrier Reef related scientific papers that call for increased environmental regulation of industry, and both contained claims that were demonstrably incorrect. In addition, in preparing this submission I have detected a major flaw in the planning of the Queensland and Federal Government’s Reef 2050 Water Quality Improvement Plan (WQIP) that could have major implications for reef ecosystem health (see below). I believe that there should be established an independent Office of Science Quality Assurance (see Appendix 1) to audit scientific work before it is considered as a basis for policy or regulation. In addition to issues with Quality Assurance I wish to address what I see as a tendency in the scientific literature to put forward alarming or dire interpretations of scientific data. Within scientific institutions there is an old adage, “publish or perish”. The “citation impact” and the number of scientific publications that a scientist produces will contribute towards any assessment for career progression. The more a scientist’s publications are cited by other scientists, or the media, then the greater their chances for career progression and receiving research funding. This, I believe, sets up an unconscious bias in scientists to look for interpretations of their data that will garner the most impact or attention. Unfortunately, gloom and doom interpretations are the most likely to achieve this end. Only two percent of GBR reefs are exposed to nutrients and suspended sediment from river runoff, and such exposure is transient. It is widely accepted that river borne suspended sediment and nutrient will primarily affect inshore reefs only during the high flow events of the wet season, and that such exposure will last from a couple of days to perhaps three weeks. These inshore reefs represent approximately two percent of total reefal area. The impact of exposing inshore reefs to transient, high concentrations of nutrients is likely to be, at worst, “generally sub lethal and subtle”. Results of the benchmark ENCORE experiment that exposed in-situ GBR patch reefs to high concentrations of nutrients for 6 hours a day, every day for 430 days found the impacts to be “generally sub-lethal and subtle and the treated reefs at the end of the experiment were visually similar to control reefs.” In contrast to the treated ENCORE patch reefs the inshore reefs of the GBR adjacent to agricultural areas are likely to spend, annually, between 94.2 to 99.5 percent of days in ambient, low-nutrient water conditions. Crown of Thorns Starfish (COTS, Acanthaster planci) A numerical model used to support the case for water quality influences on COTS outbreaks employs a statistical model that does not represent the experimentally observed high rates of survivability of COTS larvae in low chlorophyll conditions. The modelling should be repeated using an appropriate statistical model. There is a major flaw in the Queensland and Federal Government’s Reef 2050 Water Quality Improvement Plan. In the quest to improve water quality for corals and seagrass the WQIP targets reducing agriculture derived nutrient inputs to the GBR lagoon by in excess of 50% by 2025 within four out of six Queensland regions. Incredibly, the WQIP does not consider the wider ecosystem consequences to the food web of the proposed reductions in nutrient inputs. These consequences were investigated and detailed in a CSIRO report that describes food-web modelling conducted under the National Research Flagship – Water for a Healthy Country. The CSIRO found that the food-web implications of reducing nutrient inputs to the GBR by just 10% over 20 years were that populations of many marine species, including those of protected animals, would be reduced by up to more than 50% in some coastal areas. This would be a conservation disaster. Nowhere in the Reef Scientific Consensus Statement upon which the WQIP is based has the CSIRO report been considered or discussed. The WQIP should be suspended while the CSIRO report and its implications are properly considered. Body of Submission Office of Science Quality Assurance Science is currently in the midst of a replication crisis. Revelations from the scientific literature indicate that major systemic failings exist in science Quality Assurance (Ioannidis, 2005, 2014; Larcombe and Ridd, 2018). Authors and industry have reported the frequency of irreproducibility of scientific results at around 50% (Hartshorne and Schachner, 2012; Vasilevsky et al., 2013; The Economist, 19/10/2013; Larcombe and Ridd, 2018). That is, around 50% of published scientific results are not reproducible. This situation creates a significant impediment to decision making for those looking to incorporate scientific findings into policy, industry activities or investment decisions. The utilisation of invalid science represents risk in terms of inappropriate policy and wasted expenditure. There are certainly Quality Assurance issues surrounding published environmental science in Australia. I have performed partial audits upon two GBR related scientific papers that call for increased regulation of the Australian fishing industry and found profound errors in both. The first (Edgar et al., 2018) asserts that rapid declines have occurred across Australian fishery stocks, including the GBR. The graphs displayed in the Edgar et al., 2018 and displayed in Figure 1 claim to show statistically significant declines in large fish biomass in ‘Limited fishing’ and ‘Open access’ fishing areas around Australia. However, the decline in ‘Open access’ areas is clearly not statistically significant because the confidence band (red shaded area) can contain the null hypothesis (i.e., a line where the population slope = 0, Fig. 3). This is a fundamental concept in statistics and this error should have been detected in peer review. Edgar et al. (2018)’s paper received national media attention that created public concern and it was also, I understand, discussed heatedly in the Senate. An independent Office of Science Quality Assurance (Appendix 1) auditing or checking policy-relevant scientific papers could have detected this error very early and avoided the propagation of unnecessary public concern and debate. Figure 1. (Modified after Edgar et al., 2018) Best fit trends in the total biomass of large fishes in differing fishing zones around Australia. The 95% confidence bands are shown by shading. In the case of the “Open access” chart, it is clear that a line of zero slope (the green line that I have added) is contained in the confidence band. This indicates a lack of statistical significance for the trend (Yamane, 1967). The second, Purcell et al. (2016), called for increased regulation of the sea-cucumber fishing industry. One of the several arguments put forward to support their case was that sea cucumbers excrete materials that result in an increase in pH and total alkalinity of surrounding water, and therefore may buffer at local scales the effects of ocean acidification and facilitate coral calcification. This is an erroneous claim, the work they cite (Schneider et al., 2011, 2013) actually shows the complete opposite; that the presence of sea-cucumber will decrease the local pH of surrounding water (i.e., it will become more acidic). Schneider et al. (2013) expressly state that “The CaCO3 saturation state in the incubation seawater decreased markedly due to a greater increase in dissolved inorganic carbon (DIC) relative to total alkalinity (AT) as a result of respiration by the animals.“ When the CaCO3 saturation state in seawater decreases so does the carbonate ion concentration and this reduces the rate of calcification of marine organisms (Hoegh-Guldberg et al., 2007). It may seem surprising that the erroneous claim and diagram detailed in Fig. 2 can make it past four well credentialed authors and three peer reviewers active in the field. Especially in a paper calling for increased regulation and control of an industry where such recommendations, if implemented, would impose unnecessary costs, red tape and potential losses of livelihood. Clearly, there is evidence that all is not well in the environmental sciences and that there is a need for an independent Office of Science Quality Assurance (Appendix 1).