Complaint….Violated MMC policies…Scientific Misconduct

November 7, 2012

From: Dr. Corey S. Goodman

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

Re: Request that DOC OIG investigate allegations that Marine Mammal Commission

Exec. Director Dr. Timothy Ragen, in the review and release, and later private reversal of

the key conclusion, of his MMC Report on “Mariculture and Harbor Seals in Drakes

Estero, California,” violated MMC policies, FOIA, and the MMC Scientific Integrity Policy

Dear Inspector General Zinser,

I request that the Department of Commerce Office of the Inspector General (DOC OIG),

initiate an investigation into allegations of misconduct by Dr. Timothy Ragen, Executive

Director, Marine Mammal Commission (MMC). The complaint presented below alleges

that Dr. Ragen violated MMC policies, rules, and guidelines, the Federal Freedom of

Information Act (FOIA), and the MMC Scientific Integrity Policy. This complaint alleges:

• Publicly Dr. Ragen claimed to be transparent, inclusive, and to provide equal

access, and to be independent, unbiased, and without conflict, but

• Privately Dr. Ragen was secretive, exclusive, dependent upon NPS, biased, and

conflicted, and gave NPS inappropriate access, and veto power including

o Access to documents not provided to other parties,

o Ability to critique work of other parties without disclosure or comment, and

o Power to not respond to questions and not participate in open discussions.

As a result of Dr. Ragen’s inappropriate actions, the MMC Report was:

• Not an independent review of NPS science as claimed by MMC, and

• Not a legitimate independent peer review of the draft EIS as claimed by NPS.

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