Fodor has argued that observation is theory neutral, since the perceptual s
ystems are modular, that is, they are domain-specific, encapsulated, mandat
ory, fast, hard-wired in the organism, and have a fixed neural architecture
. Churchland attacks the theoretical neutrality of observation on the groun
ds that (a) the abundant top-down pathways in the brain suggest the cogniti
ve penetration of perception and (b) perceptual learning can change in the
wiring of the perceptual systems. In this paper I introduce a distinction b
etween sensation, perception, and observation and I argue that although Chu
rchland is right that observation involves top-down processes, there is als
o a substantial amount of information in perception which is theory-neutral
. I argue that perceptual learning does not threaten the cognitive impenetr
ability of perception, and that the neuropsychological research does not pr
ovide evidence in favor of the top-down character of perception. Finally, I
discuss the possibility of an off-line cognitive penetrability of percepti
on. (C) 2001 Cognitive Science Society, Inc. All rights reserved.