Happy Tuesday! Our word of the day is Integrity!
In·teg·ri·ty
/inˈteɡrədē/
noun
- 1.the quality of being honest and having strong moral principles; moral uprightness: “he is known to be a man of integrity”
I have no doubt that this will be quite a long post. I PROMISE if you follow through to the end, it will be TOTALLY worth it!
If you remember last week, when Theodore Roosevelt National Park released their Draft Environmental Assessment (EA), we sent an email to Superintendent Angie Richman – several actually! The one we are talking about for the purpose of today is the one where we reminded her about 43 CFR § 46.135.
What is CFR?
Code of Federal Regulations.
What is the Code of Federal Regulations?
The Code of Federal Regulations (CFR) is the codification of the general and permanent rules published in the Federal Register by the departments and agencies of the Federal Government.
What does 43 CFR § 46.135 say?
43 CFR § 46.135 states: Publications incorporated into NEPA analysis by reference must be listed in the bibliography. Such publications must be readily available for review and, when not readily available, they must be made available for review as part of the record supporting the proposed action.
What does that mean?
In our case it means that if Theodore Roosevelt National Park references papers/reports or documents in a report that they are releasing to the public, in this case, their Draft EA, they have to make sure that those documents are made available to the public to review.
Last week when the Draft EA came out on September 25th, we were talking to our lawyers as we both did our initial skim over the Draft EA. We noticed on page 63 of the Draft EA that the park cited a 2020 survey where they stated:
“According to a 2020 survey, 49 percent of the 1,474 visitors interviewed supported the ongoing presence of the horse herd in the South Unit (Brownlee et al. 2020)”
It seems odd, doesn’t it, that ONLY 49% of people supported the ongoing presence of horses in the Park? Even more odd, is that this seems to imply that 51% do NOT support the horses being in the park, correct? That is pretty simple math.
Our lawyer told us, “We need to get a copy of this Brownlee report.” So, I sent my email off to Superintendent Richman. I also let her know there were several documents referenced throughout the document that we would also need to be able to look at. She immediately replied letting me know they were working on a solution to this issue.
Yesterday, October 2, 2023, a full week after the Park released the Draft EA, they did a “document dump” – I think I counted some 78 documents that were uploaded to the Park Planning website. Superintendent Richman emailed me letting me know the documents had been uploaded and also added, “Some of these documents are not publicly accessible and we will have a pdf up shortly with links to find them.” So, there are even more documents coming.
Last night our lawyer called to talk to me about the Brownlee report.
Remember, the Park told us that the Brownlee report stated that “49 percent of the 1,474 visitors interviewed supported the ongoing presence of the horse herd in the South Unit”
When you look at the Brownlee report, you will see that is not entirely true.
If you look at page 57 of the Brownlee report, you will see that:
- #1 of all of the visitor opinions that Brownlee polled, (22 listed on that page) is that the park “Maintain the herd of horses in the S. Unit of the park”.
- The report offers 3 degrees of support – Strongly support, Support, Somewhat Support – and then a Neither oppose or support option, followed by 3 degrees of opposition: Somewhat Oppose, Oppose, and Strongly Oppose.
49.16% of the people polled STRONGLY SUPPORT that the Park “Maintain the herd of horses in the S. Unit of the park”. 33.92% SUPPORT that the Park “Maintain the herd of horses in the S. Unit of the park”. And 6.05% SOMEWHAT SUPPORT that the Park “Maintain the herd of horses in the S. Unit of the park”.
I am not sure how good everyone is at math, but to me, it would seem that 89.13% of the people polled SUPPORT, to some degree, that the Park “Maintain the herd of horses in the S. Unit of the park”.
WOW!
49%/89% potato/potato right?
Are you upset?
Feel deceived?
Hang on, we aren’t done yet!
Remember at the beginning where we shared the Park’s statement:
“According to a 2020 survey, 49 percent of the 1,474 visitors interviewed supported the ongoing presence of the horse herd in the South Unit (Brownlee et al. 2020)”
This is simple math. When you read that, if the Park is telling us that 49% of people polled supported the ongoing presence of the horse herd in the South Unit, what does your brain tell you about the percentage of people who do NOT want the park to maintain the horse herd in the South Unit?
My head said 51%.
Let’s check the Brownlee report, shall we….
According to the Brownlee report, 1.67% of visitors polled SOMEWHAT OPPOSE that the Park “Maintain the herd of horses in the S. Unit of the park”. 2.19% OPPOSE that the Park “Maintain the herd of horses in the S. Unit of the park”. AND 0.52% STRONGLY OPPOSE that the Park “Maintain the herd of horses in the S. Unit of the park”.
4.38% of visitors polled OPPOSE, to some degree, that the Park “Maintain the herd of horses in the S. Unit of the park”.
WOW!!!!!
4.38% is QUITE a difference from the implied 51% the Park would have us believe.
Well, you might say, they OBVIOUSLY just looked at that first column – the visitors who STRONGLY supported the horses.
Ummmm
NO!!
The VERY NEXT paragraph on page 63 of the Draft EA talks about the Longhorn Cattle:
“Based on a 2020 visitor survey, 43 percent of the 1,474 visitors surveyed supported or strongly supported the ongoing presence of the cattle herd (Brownlee et al. 2020).”
NOTE: They used the terminology “SUPPORTED OR STRONGLY SUPPORTED” meaning, they were fully aware of the columns with varying degrees of support and opposition.
So then…
WHY wouldn’t the Park use more than one column for the horses?
Good question!
This report became the backbone of their response to the economic questions raised by those 19,000 people who commented during the last public comment period.
Page 9 of the Draft EA states:
“Action alternatives considered to be reasonable (40 CFR 1508.1(z)) must be technically and economically feasible and must meet the purpose of and need for the proposed action. Appendix B provides a comparison of the alternatives.”
Page 63 is where they begin discussing “The Park’s Economic Contributions” – citing the Brownlee report. Then, after every alternative – either total elimination of the herd or the removal of 130-160 of the current 200 horses, the Park tells us REPEATEDLY: “The continued presence of horses in the South Unit would have only a small relative incremental contribution on the cumulative regional economic conditions given the other visitor opportunities at the Park and nearby attractions.”
What does all of this mean?
- If you have NOT read the Draft EA yet – you need to read it COMPLETELY!
- We ALL apparently have at least 78 other documents to read through and fact check the Park’s report against.
- As we have REPEATEDLY said, the Park gave us a document that supported their decision to eliminate the wild horses from Theodore Roosevelt National Park. THIS is a prime example of how they did that!
Given that the Park made those 78 documents available a full week after the Draft EA was released…
Given that the Park itself took over 8 months to go through those 78 documents to provide us with the Draft EA…
I think it is extremely fair to request that the 30-day comment period be extended to AT LEAST 90 days to give the public ample time to review those 78 documents.
In light of the Park’s blatant attempt to misguide the public about the TRUE visitor response about maintaining the horse herd in the South Unit of the park, you have to wonder, what other “facts” stated in their Draft EA have they misled the public with?
Let’s not forget that the Park DEMANDS that the public use certifiable FACTS when we send our comments in for this process.
Is it wrong for the public to expect the same courtesy from the Park in return?
Apparently, it is!
THIS is ONE example.
THIS is why we are working with Eubanks & Associates
THIS is why we keep telling you to NOT accept everything in this Draft EA as FACT. There are holes all over the “FACTS” in this document!
THIS is why Chasing Horses Wild Horse Advocates needs your support!
The Fight for the Spirit of the Badlands, has only just begun.
I am a nurse RN. I returned to a noted Jesuit University to study psychology.
A semester was spent on How Statisics LIE. Please don’t remove ICONIC Unique Beloved Horses as noted by Theodore Roosevelt; due to faulty statistics. Any concern to this matter would be appreciated.
Sincerely Mrs Walters