PEEReview

A Publication of Public Employees for Environmental Responsibility

Whales Held Hostage by White House
A
proposed plan for ship speed limits to protect
the highly endangered North Atlantic right
Fall whale is being held up by White House offi-
cials due to opposition by foreign shipping interests.
2007 Ship strikes are the leading cause of death for the right
whale, considered one of the planet’s most threatened
animals with fewer than 300 left in existence. In an
unusual move, the White House Council of Economic
Advisors is reviewing causes of right whale deaths, a
task already done by marine experts.
y
Holida On June 26, 2006, the National Oceanic and Atmo-
ains
Barg spheric Administration (NOAA) proposed speed lim-
terfold
see cenetails
f o r d its of 10 knots (or 11.5 miles per hour) for shipping Ships are so large and move so fast that many ship strikes
along the eastern seaboard between Florida and New are discovered only when a vessel steams into harbor with a
England during right whale migration. No action carcass pinioned on its prow.
has been taken on the plan for a year following the Save the Whales from Dick Cheney
end of public comments, despite the urgency stated by
NOAA. Since the public comment period on the NOAA plan
ended back in October 2006, the plan is being held up
Massive container ships move at speeds that do not al- by the White House Office of Management & Budget
low the slow-moving whales lolling on the surface to long past the normal 90-day review period. Foreign
get out of the way before being struck. Last year for shipping companies are lobbying the White House,
example, an 800-foot long container ship steamed into
continued on page 12
Baltimore Harbor with the body of a rare sei
whale impaled on its prow. Due to the vessel
size and speed, its crew did not even notice “Angler” and the Klamath Fish Kill
the impact with a 17,000 pound male sei, a The Washington Post reported that Vice President
species only slightly smaller than the blue Dick Cheney, with the Secret Service code name
whale, the largest creature on earth. Angler, intervened to order drastically reduced
water flows in the Klamath River leading to the
“Speed limits are the indispensable ingredi- largest fish kill in the history of the Pacific North-
ent in a winning recovery strategy for the west. He directed that sci-
right whale,” stated New England PEER Di- entific analyses be overrid- One of the easiest
rector Kyla Bennett, a former federal biolo- den to benefit agricultural ways to give to
gist, who has waged a three-year long effort interests key to the Bush- PEER is through the
for speed limits and other ship strike reduc- COMBINED
Last year, there were four
known right whale deaths from
collisions with ships. Right
tion measures. “The current official ‘Poten-
tial Biological Removal’ level for the right
whale is at zero, meaning that the premature
Cheney re-election effort.
In the ensuing fish kill, at
least 33,000 adult salmon,
FEDERAL
CAMPAIGN R
Check # 12057 on
whale calves are particularly your pledge form.
vulnerable due to their loss of even one more whale could tip the continued on page 12
undeveloped diving capability. species into a tailspin toward extinction.”

u Interior Attorney Charged with Secrets Act Violation, page 4

INSIDE u
u
Take the New Jersey Toxic Mystery Tour, page 7
Army Wars on Environment—and Its Own Staff, page 9
 From the Executive Director
Pay No Attention to the Man Behind the Curtain
T
his August, a vacationing President Bush issued an Ex-
ecutive Order directing federal land management agen-
cies to do all they can to “expand and enhance hunting
opportunities.” With dwindling poll numbers and time left in of-
fice, we can expect to see more unilateral acts like this edict as
the Bush administration struggles to cement its legacy before the
sands of power completely drift away.
While this order does not overturn any conservation laws, it
establishes a preference for hunting at the expense of all other
activities on public lands. It also directs federal agencies to de-
fer to “private property rights and State management authority
over wildlife resources” so as to foster “productive populations
of game species and appropriate opportunities for the public to
hunt those species.”
The order reads like it was written by a lobbyist (or by Dead-Eye
Dick Cheney). The President seems to be saying you can never
have too many deer and that public lands should be operated
as a salad bar for trophy animals. And, indeed, the NRA and
other hunting groups issued same-day self-congratulatory news
releases proclaiming their joy at this presidential fiat.
On the other hand, the order may amount to no more than mean-
ingless political pandering in that it stipulates any actions must
Mission Statement
PEER protects public employees who protect our environment. We are a service organization for local, state, federal
and tribal law enforcement officers, scientists, land managers and other professionals dedicated to upholding
environmental laws and values. Through PEER, public servants can choose to work as “anonymous activists” so
that public agencies must confront the message, rather than the messenger.
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tel: 520-906-2159 email: swpeer@peer.org
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tel: 615-313-7066 email: tnpeer@peer.org
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 PEEReview
be “consistent with agency missions.” By its terms, the directive
“does not create any right…or privilege, substantive or proce-
dural, enforceable at law or in equity by any party against the
United States [or] its departments.”
The underlying motivation is the steady decline of hunting in
the U.S. The number of hunters has dropped from 14 million to
12.5 million in the past decade while the percentage of hunters
in the population fell by almost half in a generation, with barely
4% identifying themselves as hunters today. Those who do are
overwhelmingly middle aged and older white males, meaning
these numbers will likely continue to slump. At the same time,
other forms of outdoor recreation are on the rise. For example,
bird-watching and wildlife photography are up 14% in the last
ten years, attracting nearly six times as many people as hunt-
ing.
No presidential order will reverse this dynamic or spark a hunt-
ing renaissance. Moreover, the first time this Bush order is used
to argue for reducing off-road vehicle traffic to maximize hunt-
ing opportunities, there will be a hue and cry to restore greater
agency land use discretion. In any event, the power of this and
other presidential pronouncements will quickly fade as the coun-
try finally begins to moves forward again.
— Jeff Ruch
PEER DC Headquarters Staff
Executive Director • Jeff Ruch
Associate Director • Carol Goldberg
Legal • Paula Dinerstein & Adam Draper
Membership • Justin Haas
PEEReview Layout • Dana Serovy
PEER Board
Chair • Howard Wilshire (USGS, retired)
Member • Magi Shapiro (Army Corps, retired)
Member • Louis Clark (G.A.P. President)
Member • Frank Buono (National Park Service, retired)
PEEReview is the quarterly newslettter of
Public Employees for Environmental Responsibility
2000 P Street, NW • Suite 240 • Washington, D.C. 20036
tel: 202-265-7337 • fax: 202-265-4192
email: info@peer.org • website: http://www.peer.org

Aerial Gunning in the Cross-hairs
PEER is leading a coalition of 27 conservation organizations
pressing the U.S. Department of Agriculture to cut off funds for
aerial coyote hunts. The coalition filed a formal petition follow-
ing the deaths of two more
USDA Wildlife Services
Poison Ban Advances
The U.S. Environmental Protection Agency has called for pub-
lic comment on a PEER-led petition banning two of the most
widely used and deadly poisons for killing wild mammals.
The two toxicants are sodium cyanide (used in M-44 ejectors)
and sodium fluoroacetate, commonly called Compound 1080,

Copyright. James Balog

federal agents this summer
on the grounds that aerial used in “livestock protection collars” strapped onto the heads
gunning, as the practice of sheep and goats. Both are classified by EPA as having the
is known, is excessively highest degree of “acute toxicity.” The poisons are distributed
dangerous, demonstrably by U.S. Department of Agriculture’s Wildlife Services.
wasteful and biologically Each year, M-44s account for the deaths of approximately
counterproductive. 12,000 mammalian carnivores, out of a total of more than 1.6
On June 1, 2007, two fed- million birds, coyotes and other wildlife killed last year by
eral agriculture agents died Wildlife Services.
when their plane crashed Compound 1080, a colorless, odorless, tasteless, water-soluble
during an aerial gunning toxin, is classified as a chemical weapon by several countries
trip in Wayne County, for its potential threat to water supplies. Wildlife Services’
Utah. This brings the death own records show that livestock protection collars routinely
total to 11, as well as 27 in- go missing and that their poison-containing pouches easily get
juries, from aerial gunning punctured on sharp objects like brush, rocks, or barbed wire,
accidents. creating an uncontrolled biohazard.
21st Century Wildlife Management.
Coyote hunts do not provide relief
On July 30, 2007, South Compound 1080 is already banned in California and Oregon
to ranchers as studies show that Dakota game agents and is explicitly allowed for use in only eleven states. EPA
the coyotes compensate by either crashed an airplane during had also previously banned Compound 1080, but, during the
bearing larger litters or permitting a coyote hunt – the fourth
more animals in the pack to breed. Reagan administration, the agency reversed itself.
such aircraft crash in the
state since 1998. After the Among many concerns, the petition cites:
July accident, South Dakota grounded the remaining plane in its
fleet and the agency is reviewing whether to discontinue its aerial • USDA Inspector General audits showing sloppy inven-
gunning program. tory control could lead to theft or black market sale of
these “dangerous biological agents” that can be used to
Then in September, two more federal agents suffered serious inju- poison urban water supplies;
ries in a helicopter crash while conducting a coyote hunt in Pecos
County, Texas. • The deaths of pet dogs and other domestic animals, as
well as carrion or other non-targeted animals that feed
“Chasing animals from low-flying aircraft is so inherently dan- on poisoned carcasses, including sensitive species such as
gerous that it should be stopped before any more public servants wolves, grizzly bears, and California condors; and
die,” stated PEER Executive Director Jeff Ruch. “USDA needs
to rethink the wisdom of this • The ready availability of non-lethal alternatives for
entire program.” predator control.

The vast majority of aerial
gunning takes place as part
of a $100 million a year fed-
eral agency called Wildlife
Services, an arm of the U.S.
Department of Agriculture.
In 2006, Wildlife Services
killed 35,503 animals by
aerial gunning, principally
coyotes but also badgers,
bobcats, red foxes, grey
wolves, feral hogs and even
ravens.
Another One Down. Aerial gunning
is risky because pilots are often
distracted, flying at low altitudes
with little margin for error. In several
instances, pilots have flown into
power lines, trees and even land
formations.
Since relatively few livestock are killed by predators, the 15
groups behind the petition argue that the risks from highly
toxic agents unwarranted. USDA figures show that in 2005,
more than 20 times as many cattle were killed by weather,
rustlers and other causes than by predators, which accounted
for an infinitesimal 0.18% of losses.
“This petition makes a compelling case for EPA to act now
for the protection of public health and the environment,” com-
mented PEER Senior Counsel Paula Dinerstein. “In all like-
lihood, however, the final decision on whether to take these
commercial poisons off the market will be made by the next
administration.”

Fall 2007 
 Interior Department
Interior Lawyer Charged with Telling Secrets
A
n Interior Department attorney who revealed extensive
ongoing mismanagement of Indian properties faces ter-
mination from his job for disclosing these problems to a
reporter. The government is invoking the Trade Secrets Act, an
obscure criminal statute, as the basis for proceeding against him.
Robert McCarthy, a Field Solicitor, is the chief legal officer in
Southern California responsible for overseeing proper handling of
properties of individual members of Indian tribes held in trust by
Interior. McCarthy documented massive losses due to agency mis-
steps but the problems persist, costing Native Americans millions
of dollars a month in lost revenues. A July 20, 2007 audit report by
Interior’s Office of the Special Trustee for American Indians vali-
dated McCarthy’s claims that his agency failed to collect millions
of dollars in lease revenues owed to Indian landowners.
McCarthy provided a reporter for the Palm Springs Desert Sun a
copy of his Inspector General disclosure with individual names
blacked out. The reporter wrote a story on April 10, 2007. Four
months later, Regional Solicitor Daniel Shillito proposed that Mc-
Carthy be fired for violating the Trade Secrets Act, which prohibits
the release of “confidential” financial information.
In McCarthy’s case, however, this arcane act does not apply be-
cause he revealed no names or any confidential information. More-
over, the Trade Secrets Act only prohibits releases which damage
economic interests of the submitter but McCarthy’s disclosures
benefit property holders by identifying unjustified losses.
Significantly, Shillito, McCarthy’s predecessor and supervisor,
was supposed to clean up asset mismanagement identified back in
1992 that McCarthy found had never been addressed. One major
problem is Interior’s inability to even track revenues owed to In-
Mickey Mouse Maneuver
Poetic Justice Corner
Former Interior Deputy Secretary Steven Griles is now
behind bars despite a bid by the lawyers for the high-
est ranking Bush official to confess to a felony that he
instead work for The Walt Disney Company—500 hours
of community service with a Disney-funded program
called WOW for the “Wonderful Outdoor World.” WOW
had already approved a slot for Griles in which he would
fundraise, recruit corporate partners and lobby “govern-
ment entities.” Ironically, Griles was convicted for hiding
his ties to a “green scam” group peddling corporate influ-
ence throughout Interior, an activity he still regards as a
community service.
Larry Craig: Stranger than Fiction
Regardless how one feels about the implosion of Craig’s
career due to his bathroom antics, he was no friend to
environmental employees. In cases ranging from his ef-
forts to axe the Fish Passage Center {see PEEReview
Spring ‘07} to his purge of Idaho BLM Director Martha
Hahn, Craig could generally be counted on to do the
wrong thing—with vindictiveness.
 PEEReview
Being Right is Beside the Deer in the Headlights? The
Point. Robert McCarthy has been tenure of Solicitor David Bernhardt
vindicated by audits but faces has seen a deepening decline in
possible dismissal anyway. Interior’s legal unit.
dian property-holders. This failure is at the heart of what is called
the Cobell case, a more than decade-long effort by tribal members
to force an accounting for, and repayment of, what is owed.
The federal government’s liability to the Cobell plaintiffs and to
tribes themselves runs into billions of dollars. McCarthy’s revela-
tions show the accounting problems have yet to be fixed and thus
the future liability of the government grows greater every day.
Ironically, Interior was sanctioned for making “groundless” legal
motions in the Cobell case for asserting the Trade Secrets Act as a
basis for denying requested lease information.
“Interior invoking the Trade Secrets Act to cloak its own malfea-
sance is not only baseless but somewhat chilling,” stated PEER
Executive Director Jeff Ruch, whose organization is representing
McCarthy. “Congress needs to step in now to stop Interior from
digging this gaping financial hole any deeper.”
McCarthy has also been named as a witness against the govern-
ment in Cobell and becomes subject to a special court order en-
joining any “retaliatory action or making threats of such action
against any person who has been identified as a Potential Witness.”
Paradoxically, Interior proposes to fire McCarthy for the very same
disclosures that have made him into a protected witness.
Meanwhile, the August 9th proposed dismissal is still pending.
The decision was first assigned to a senior attorney, and then el-
evated to Interior Solicitor David Bernhardt, but in September was
transferred to the Regional Solicitor in Alaska. “The Solicitor’s
Office has been playing hot potato with Robert McCarthy’s career
for the past two years,” Ruch added, noting that McCarthy has
vigorously raised these concerns since 2005 with the only result
being that he is barred from his office, ordered to work from home,
denied law library access and precluded from using Department
intranet or even hooking up a fax – months before the proposed
termination.

Rangers to the Rescue
R
eckless off-roading has become an
acute law enforcement problem and
is now the single greatest threat to
American landscapes, according to a new
coalition of rangers and public land manag-
ers assembled by PEER. Rangers say tough
new policies, such as suspending hunting
and fishing licenses and, in extreme cases,
confiscating vehicles, are needed to stem
irresponsible off-road vehicle use.
The coalition, called Rangers for Respon-
sible Recreation, consists of more than a
dozen of America’s most seasoned law
enforcement and natural resource manage-
ment specialists from every major public
lands agency covering several different
administrations. The coalition contends
off-road abuse is creating chaos on our
public lands and ruining the outdoors for
everyone while overburdening an already
strapped ranger force. As Don Hoffman, a
retired Forest Service wilderness ranger in
Surprise Canyon Win No Surprise
In a major legal victory, a federal court has
sided with PEER and allied groups in turn-
ing back an effort by off-road groups to end
protections for Surprise Canyon, a rare and
fragile desert stream which begins in Death
Valley National Park and flows through
Bureau of Land Management wilderness
within the California Desert Conservation
Area.
In his September 18th order, Federal Dis-
trict Judge William Alsup rejected poten-
tially precedent-setting attempts by private
individuals to invoke the 19th Century RS
2477 road rights
based on inhold-
ings on old mining
claims they pur-
chased within Death
Valley Park. PEER
has been in some
form of litigation
to protect Surprise
Canyon since 2000.
California PEER
Director Karen An ORV Runs Through It. Desert stream on
Schambach is still canyon floor was becoming a motorized trail.
Fall 2007
Bureau of Land Management
Arizona states: “Rapid population growth,
accelerating off-road vehicle sales and inef-
fectual regulation have combined to make
the indiscriminate use of off-road vehicles
the greatest threat to Arizona’s quiet, wild
places.”
From a national perspective, Jim Baca, for-
mer Director of the U.S. Bureau of Land
Management (BLM) now serving as New
Mexico’s Natural Resource Trustee, con-
tends: “There is no greater threat to our
country’s public land treasure than off-road
vehicles. Additionally, they are killing and
injuring too many young people because of
improper training, operation and inherent
safety deficiencies.”
The Rangers are also urging a congressio-
nal inquiry that accounts for the real costs
to taxpayers from off-road abuses on our
public lands, as well as augmented law
enforcement funding dedicated to coping
concerned about the future of Surprise Can-
yon. “We have our finger in the dike, and so
far it is holding. Unfortunately, this newest
generation of extreme off-roading is doing
more damage every year to these special
areas that were formerly safe by virtue of
their inaccessibility. We need more than
lip service to environmental responsibility
from groups like Blue Ribbon Coalition,
who think it is all right to destroy sensitive
habitat as long as they pick up their trash.”
Surprise Canyon is narrow and constrained
through much of its length, so off-road
vehicle use is not
possible without
Photo Credit: Daniel Patterson
ruining the creek
and the wilderness
character of the
area. With cascad-
ing waterfalls, the
creek is a haven
for hikers, as well
as desert bighorn
sheep, endangered
birds, and species
found nowhere else
in the world.
It is No Joke. Off-Road Abuse is Top Threat to
Public Lands
with the avalanche of problems from reck-
less off-roading. The group is organized
by Southwest PEER Director Daniel Pat-
terson, who assembled BLM data show-
ing ORV-related lawlessness is the number
one crime category on public lands in the
Southwest. The introduction of the group
generated national press attention and its
progress can be tracked in a new campaign
center on the PEER web site.
BLM Okays “Temporary”
ORV Trails
In a slick but legally questionable move,
the Bureau of Land Management has
authorized all of its units to approve
“temporary” motorized trails. BLM
claims that the move only adopts “con-
sistent terminology” and thus evades
the environmental review required of
any significant policy change.
Under BLM’s new terminology, routes
of “finite lifespan” including those in
“periodic use” may be approved. The
August 16th directive states that routes
“must be reclaimed when their intend-
ed purpose is fulfilled” but does not ex-
plain how or provide access to funds
to restore rutted trails. Nonetheless,
the memo says that it serve a “holistic
approach to the management of trans-
portation-related linear features.”
“Roads carved by this loophole would
likely be temporary only on paper, but
permanently harmful in on-the-ground
reality,” stated Southwest PEER Direc-
tor Daniel Patterson, who is leading an
effort to put this “holistic” genie back in
the bottle.

New Jersey
Down in the Dumps
Without announcement, the New
Jersey Department of Environmental
Protection (DEP) suddenly posted on
its website a list of 831 old landfills
that have not been properly closed,
including 149 with known groundwater
pollution. Despite the pollution threat
these old landfills pose, the state has
no apparent plans to clean them up.
Many of these sites operated prior to
the passage of environmental laws
and accepted a mix of hazardous and
toxic wastes. Similarly, many have no
or minimal pollution controls, such as
liners and leachate collection systems.
Many dumps lack even basic ground-
water monitoring. Consequently,
these long-ignored sites are a major
uncontrolled threat, with groundwater
pollution sites spread across 19 of
New Jersey’s 21 counties.
Yet many of these landfills are slated
for development, including residential
projects. Housing has already sprung
up along landfill perimeters, without
notice to purchasers. In some places,
methane gas has migrated into base-
ments and drinking water wells.
“Instead of properly closing these
dumps, DEP is focused on redevelop-
ment schemes,” stated New Jersey
PEER Director Bill Wolfe, arguing the
stealth web posting of a spread sheet
falls far short of adequate public no-
tice. “One of my first assignments at
DEP – way back in 1987 – was pre-
paring the ‘Statewide Landfill Closure
Plan.’ That plan was finished in 1988
and has been ignored ever since.”
Meanwhile, the number of “Non-Op-
erating Landfills Having Suspected or
Known Contamination” (in the jargon
of DEP) has doubled in the last few
years from around 400 identified in
2002 to more than 830 today. The full
cost for proper cleanup for all of the
old landfills has never been itemized
but would undoubtedly run into bil-
lions of dollars.
PEER is pushing to warn potentially
impacted residents and force a deep-
er review of the performance of the
DEP landfill closure program.
 PEEReview
Playing in Quicksand
C
hildren played
baseball and
rode bicy-
cles for years amidst
mounds of dangerous
toxic waste, but state
officials who knew of
the danger did noth-
ing to warn or protect
them until PEER blew
the whistle this sum-
mer. For more than
four years, officials of
the New Jersey Depart-
ment of Environmen-
tal Protection (DEP) Attractive Nuisance. Children and residents played, biked and hiked
and Bergen Tool, Inc. on the toxic waste piles at the abandoned Bergen Machine & Tool in
have quietly negotiated Hackettstown.
about what to do with
a closed factory in Hackettstown without sponsible corporate behavior.”
telling the community about the site’s dan-
For the past century, the site has been used
gers.
for various heavy manufacturing. Bergen
The soil at the former Bergen Machine Tool ran its factory from 1950 until it closed
& Tool factory contains dangerous levels in 2003. By law, the company must submit
of a human carcinogen called polycyclic a cleanup plan to DEP. But Bergen has yet
aromatic hydrocarbons (PAHs), as well as to complete a site characterization report
PCBs, volatile organic compounds, lead, – the first step in the cleanup process.
chromium, arsenic and other pollutants
above DEP safety criteria. The site is right This July, New Jersey PEER called upon
next to a residential neighborhood and kids DEP to take immediate steps to protect
can easily enter abandoned buildings hon- residents, test the ball-field and other rec-
eycombed with storage tanks and pipes. reation areas, sample nearby yards and
homes for off-site migration and finally be-
“What part of environmental protection gin to enforce toxic pollution laws so that
does DEP not understand?” asked New the company conducts a full cleanup. In
Jersey PEER Director Bill Wolfe, who response, DEP put up fences and warning
brought the status of the site to light after signs – and began edging toward possibly
a file review and visiting the site. “Bergen taking enforcement action and cleaning up
Tool walked away and left the community the site. The company has also agreed to
at risk but, even worse, DEP failed to en- excavate the site. See the story on the next
force cleanup laws designed to protect the page to get an overview of New Jersey’s
community from exactly this kind of irre- “broken” toxic waste cleanup program.
Comings & Goings
Maine PEER Director Tim Caverly, the former longtime manager of the Allagash
Wilderness Waterway, is packing it in. We will miss Tim and his wife Sue and their
contributions to PEER. Our Maine work will shift to Kyla Bennett and our New
England office.
Meanwhile, in D.C., we are staffing up. Justin Haas of Every Child Matters Edu-
cation Fund has taken over our membership program. And joining our legal staff
is Adam Draper from Lewis & Clark Law School who has done stints in both EPA
and the Forest Service.
 New Jersey
Flying Blind in a Toxic Wonderland Blame It
F on Rio
or the past five years, New
Jersey officials have not
known which are the most
dangerous polluted sites in the
Something about New Jersey stim-
state. As a result, the state cannot ulates creativity – especially when
set cleanup priorities among the it comes to explanations or rational-
approximately 16,000 contami- izations for what otherwise appear
nated sites that pockmark New to be huge regulatory screw-ups.
Jersey. Here are some recent examples:

State law directs the Department
of Environmental Protection
(DEP) to develop a cleanup pri-
ority list, but DEP allowed these What Are the Dirtiest Sites? Don’t Ask the State. New
Jersey has 6,000 toxic sites but will not prioritize among
priority rankings “to expire” so them, making all sites equal, no matter how dangerous.
that DEP could instead formu-
late “a new prioritization system
for all sites through new rulemaking,” ac- Committee back on October 23, 2006, DEP
cording to an agency decision memo. As Commissioner Lisa Jackson said –
recommended, the rankings, called the
Remedial Priority System, expired but no
replacement was ever put in place.
“For a generation, the mantra of ‘worst first’
has guided our approach to addressing New
Jersey’s profound toxic legacy,” stated New
Jersey PEER Director Bill Wolfe, a former
DEP analyst. “New Jersey cannot have a
responsible toxic cleanup program if our
DEP insists upon flying blind.”
In testimony before the Senate Environment
Closed Door Privacy
The New Jersey Department of Envi-
ronmental Protection formally rejected
a PEER petition to give the public no-
tice of its meetings with lobbyists and
to post appointment calendars of its
top officials. The rejection apparently
did not take much thought, as the deci-
sion by DEP Commissioner Lisa Jack-
son was dated July 2, 2007, the same
day the PEER petition for rulemaking
was first published for public review in
the New Jersey Register.
DEP reasoned that revealing “the iden-
tity and the sequence of the persons
with whom Department senior staff
consult could reveal the substance
or direction of the judgment or mental
processes of the Commissioner and
Department staff.” Well, duh, why did
they think we wanted it?
“The most important thing we are
doing is developing a new ranking
system to prioritize sites so that we
focus our resources on the worst
cases, those that present the greatest
risk to public health and the environ-
ment.”
Nearly a year later, no such rankings have
emerged. Moreover, Ms. Jackson has not
offered an expected due date for a ranking
system on which her agency has suppos-
edly worked for the past three years.
“A series of botched cleanups, contami-
nated schools and day-care centers and the
fiasco in the Meadowlands all are prime
examples of how a systematic ranking of
toxic hotspots would have saved taxpayers
a ton of money and lots of people loads of
grief,” Wolfe added, referring to the $212
million the state loaned developers for what
appears to be a toxic sinkhole. “Without a
coherent priority system, development pol-
itics and not public health needs determine
who gets to the top of the list at DEP and
draws state cleanup money.”
Bludgeoned by a steady stream of such dis-
closures, the DEP is now admitting that the
state’s cleanup system is “broken” but thus
far has advanced no solutions. PEER is urg-
ing a comprehensive re-write of the state
hazardous waste laws, and with each new
revelation more people are starting to listen.
• Over the Labor Day weekend,
several Ocean County beach-
es were closed due to heavy
wash-ups of untreated sewage,
syringes and tons of other filth.
Virginia Loftin of the Depart-
ment of Environmental Protec-
tion (DEP) had this to say: “I
guess it was just an unlucky
combination of events” blam-
ing a full moon high tide for the
wash-up. Adding, “I think we
had a really great summer and
this was an unfortunate event,
but it’s only a small number of
beaches that were affected.”
• At Bayshore, DEP blamed a
big fish kill on the fish. Spokes-
woman Darlene Yuhas said
the “the water quality testing
we did (six weeks ago) came
back fine” therefore the expla-
nation must be that because
menhaden “swim in extremely
tight schools” they used up all
oxygen in the water. Perhaps
it will be classified as a mass
suicide.
• After PEER found toxic soil in a
Paramus middle school, DEP’s
chief of environmental evalua-
tion Kevin Schick blamed the
media: “You made it seem like
kids are going to die. These
chemicals are found in all our
bodies…due to natural expo-
sure.” Since the chemicals are
synthetic pesticides, there is
no such thing as natural expo-
sure…except in New Jersey.

Fall 2007 
 National Park Service
Faith-Based Parks Revisited The Revolving Door

I
n August 2003, over the
objections of its geolo-
gists and even the park
superintendent, National Park
Service political appointees
approved the sale of a book
at Grand Canyon National
Park claiming that the canyon
was formed by Noah’s Flood
6,000 years ago. NPS regu-
lations require that any book
sold with the parks be “accu-
rate” and consistent with park
educational efforts. At Grand
Canyon, the park website de- Good Housekeeping Seal of Approval? Official Park Service
“Arrowhead” at Creation Museum exhibit explaining that Grand
clares the canyon is more than
Canyon was formed over Biblical rather than geologic time.
40 million years old.
After PEER exposed and protested the
book’s approval, NPS promised to conduct
a high-level policy review. Initially, that re-
view was supposed to have been completed
by February 2004, then March. In the in-
tervening years, there has been no review at
all and the book remains on sale.
This inaction is being interpreted by some
as an official endorsement of creation-
ist “Young Earth” theories. The latest in-
stance involves the new Creation Museum
that opened this June in northern Kentucky.
This is the time in a presidential ad-
ministration when appointees resign
in droves to cash in on their access.
Here are just a couple of the more no-
table recent examples:
• This summer, Interior Secretary
Dirk Kempthorne introduced “a 10-
point plan” to transform his scan-
dal-ridden agency into “a model of
an ethical workplace,” but the plan
is already in trouble. Its center-
piece – a new Conduct Account-
ability Board – was rocked by the
abrupt resignation of its chair, Mark
Limbaugh, Assistant Secretary for
Water and Science, two days after
the plan’s announcement. Lim-
baugh has gone off to lobby for
water interests – precisely the sort
The museum features the Grand Canyon as of insider dealing Kempthorne was
“evidence” for Noah’s Flood having shaped hoping to dispel.
the Earth’s surface. The Museum’s Grand • A deputy undersecretary and the
Canyon exhibit even displays the official top lawyer overseeing the Forest
NPS “Arrowhead” symbol. Service have both quit to work for
the top timber lobby, the American
By law, however, use of the Arrowhead re- Forest & Paper Association, which
quires official approval from NPS. Director had previously employed their
Mary Bomar has not yet responded to our boss, Undersecretary Mark Rey.
letter asking whether she approved the use
of the Park Service symbol at the Creation
Museum – and, if not, whether she intends Random Notes
to have the museum cease and desist. • Cape Cod National Seashore is

Saga of the Mojave Cross cracking down on nude bathers. To

catch naturalists who favor remote lo-
cations, the park admitted that it was
A unanimous 9th Circuit Court of Appeals has struck down a congressional land using “undercover” rangers.
exchange to place an eight-foot-tall cross, planted atop a 30-foot-high rock out-
cropping in the Mojave National Preserve in California, in private hands to evade • No national park in Utah is free from
an earlier court order that the cross be removed from park land. As a result, the noise pollution. Planes, motors and
six-year legal battle to take the cross down will succeed, unless the Bush Justice cell phones are usual culprits but
Department appeals to the U.S. Supreme Court. noise researcher Skip Ambrose, a
former NPS biologist, blames much
The appeals court held that a one-acre land exchange enacted by Congress in of the din on park operations that
2003 to transfer the plot on which the cross sits to a private entity promising to squander the quietude.
maintain the cross as a memorial was invalid, as a transparent attempt to thwart
a permanent injunction against display of the Latin cross. Local Congressman • Mr. Stealth, VP Dick Cheney, flew
Jerry Lewis (R-CA) had inserted the land exchange earmark into the massive FY into Salt Lake City to address the
04 Defense Appropriations Act. PEER Board member Frank Buono, the former shadowy Council for National Policy,
assistant superintendent at Mojave, is the lead plaintiff in the case (now re-titled whose secret membership is dedi-
Buono v. Kempthorne) brought by ACLU of Southern California. cated to “a free-enterprise system,
strong national defense and sup-
“This case is about whether government officials may place their religious prefer- port for traditional Western values.”
ences above the law,” stated Buono, who through PEER led a coalition including Cheney spoke from an undisclosed
the Jewish War Veterans and conservation groups in opposing Lewis’ land ex- location with unrecorded remarks.
change rider. “In matters of religion, federal officials’ oaths to uphold the Constitu- His speech was followed by one from
tion seem to take a holiday.” Mitt Romney.

 PEEReview
 U.S. Army
Army Expansion Carries Big De-Regulating
Environmental Costs the Environment

T
he U.S. Army foresees significant In a quiet mid-summer move, the
adverse environmental consequenc- U.S. Army repealed the federal reg-
es from its expansion plan for U.S. ulations governing its air and water
bases. Most of the harm will be felt around pollution, toxic waste, resource pro-
installations in the West, according to a tection and noise abatement practic-
PEER analysis. The “force structure modi- es, according to documents posted
fications” will add 30,000 combat sup- by PEER. This repeal leaves in its
port troops and up to six combat brigades place only internal guidelines, which
through FY 2013. cannot be externally enforced.

The upper range scenario for stationing In a July 20, 2007 Federal Register
“multiple” brigades would cause “high” notice, the Army declares that envi-
adverse effects for air pollution, erosion, ronmental regulations governing the
water usage, energy consumption, wildlife, service are repealed effective imme-
and noise, air or surface traffic at virtually diately, offering the following cryptic
every installation. In many instances, ad- yet obtuse rationale:
verse effects are assessed as “very high”
“The Office of the Assistant Chief
meaning the impact could not be avoided Military Now Leading Wildlife Agency. Acre-
of Staff for Installation Man-
through mitigation. Unfortunately, the for-acre Defense lands contain three times
as much critical habitat for threatened and agement…has concluded this
Army is under no legal obligation to mini-
endangered species than national parks, forests regulation is obsolete. This reg-
mize pollution or environmental harm. or refuges. ulation has been extensively re-
In related actions, the Army is seeking to Congress shelving the Fort Carson expan- vised and has been determined
significantly expand certain western bases, sion. Expansion plans for Yuma Proving that the procedures prescribed
most prominently Fort Carson in central Grounds, revealed by PEER, indicate that in the regulation are for Army
Colorado and the Yuma Proving Ground in the Army is seeking to withdraw as many officials, and not intended to be
southwestern Arizona. These proposals are as 500,000 acres of federal lands from pub- enforced against any member of
proving controversial in both states, with lic use. the public. As a result, the regu-
lation does not affect the gen-
eral public. Therefore, it would
Mega-Contracts and Outsourcing be helpful in avoiding confusion
if 32 CFR Part 650 is removed.”
The Army is preparing to consolidate all of its environmental contracting into three
national mega-contracts worth nearly $1 billion, according to internal documents re- “On matters of pollution, hazardous
leased by PEER. This super-centralization will cause dramatic decreases in flexibil- waste and resource conservation,
ity, accountability and quality that will wipe out any envisioned cost savings. the Army has just put itself on a vol-
untary honor system,” stated PEER
The Army Environment Command is preparing acquisition plans for three “enter-
Executive Director Jeff Ruch. “In-
prise-wide” mega-contracts worth $840 million over their five-year terms. These
credibly, the Army states this does
national contracts would subsume all environmental compliance, natural and cultural
‘not affect the general public’ and
conservation work on each major base. The first such “ID/IQ” (indefinite delivery/
therefore the public will have no say
indefinite quantity) master contract is slated to be awarded during the fourth quarter
in what anti-pollution rules the Army
of 2008.
must follow.”
Against this backdrop is the controversial role of contractors doing military environ-
The move also effectively down-
mental work. Under current law (the Sikes Act) resource management may not be
grades environmental work from a
contracted out to private firms. Under pressure from PEER, the Army has dropped
“must fund” category to a discre-
plans to contract resource management at the Army’s oldest base, West Point but a
tionary status, which, given finan-
similar proposal for the largest base, the White Sands Missile Range, is proceeding.
cial strains on the Army, may cause
Previously, PEER settled a lawsuit blocking such contracting at Edwards Air Force
sizeable reduction in support for en-
base in California. We are gearing up to mount legal challenges against any other con-
vironmental programs.
tract packages that include environmental and resource management responsibilities.

Fall 2007 
 PEER Perspective
The New Public Bathroom Etiquette
D Army Corps Project Manager Keith
Watson
A Corps beach “re-nourishment” in Surf City, New
Jersey turned out terribly wrong. The Corps dredged up
more than a thousand World War I munitions and scattered
them over the beaches, prompting closures. Corps Manager
Watson warned that it was unlikely any of the explosives
would detonate but if one did it would be very bad. City
officials seem equally upset by the Corps demanding a local
match to pay for cleaning up the mess – a stance exhibiting
so much nerve it almost qualifies as bravery.
D California Governor Arnold
Schwarzenegger
A Republican member of the state Fish & Game
Commission was forced to resign after circulating a packet
of information about the damaging effects of lead bullets.
Judd Hanna, a Republican and a hunter, was concerned
about wildlife lead poisoning, particularly in the endan-
gered California condor. The packet, consisting of scientific
journal and other articles, enraged GOP legislators who
called for Hanna’s head. The Governor’s office claims,
however, Hanna was removed for reasons of “geographic

C
diversity” so that a Southern Californian could serve.
Lake Roosevelt NRA Hmm…Geographic diversity sounds like a pretext only a
Superintendent Debbie Bird “girly man” might use.

D
Although shoreline campers at Lake Roosevelt National
Recreation Area are required to carry portable toilets, many BLM Director James Caswell
eschew that amenity leaving their deposits scattered along Days after he was confirmed, pledging his “com-
the shoreline of the 129-mile lake in eastern Washington. mitment to balance, cooperation, collaboration
Superintendent Bird is trying to build local awareness of and sharing,” Bureau of Land Management Director James
the problem as her staff has Caswell eliminated public
been cut by more than half “His genius [is that] he builds networks and puts comment on thousands of
in the past decade while an- the right people in the right places, and then trusts agency decisions affecting
nual visitation is now at 1.5 natural and cultural re-
million and growing. “It’s them to make well-informed decisions that comport sources. Caswell declared
hard for me to get into the with his overall vision.” all “routine actions in the
mentality of people who BLM’s forestry, grazing,
bring their families out — Interior Department Deputy Assistant Secretary Paul oil and gas and recreation
and don’t think about what Hoffman marveling at the brilliance of his former boss programs are now among
they’re leaving behind for Dick Cheney those that do not require
the next family.” an EA [environmental as-

D
sessment] or EIS [environ-
Deputy Assistant Interior Secretary mental impact statement].” For the previous 30 years, this
Todd Willens “categorical exclusion” exemption was limited to truly
Willens left the employ of Rep. Richard Pombo minor activities like Christmas tree cutting or mushroom
(D-CA), who was ousted from office by voters in 2006 in gathering. Lately, however, it is oil, gas and methane rigs
large part for his anti-environmentalism, to land inside the that have been sprouting on BLM lands like mushrooms.
Interior Department overseeing the National Park Service.
This summer, Willens reversed a Park Service recommen-
dation that the Everglades remain on the World Heritage
endangered list. “I changed the last sentence of our report
and said we wanted to be taken off.” After all, how much
difference could one sentence make?
D
ing to
Otero County Commissioner Mike
Nivison
Break out the black helicopters; the U.N. is com-
New Mexico. An attempt to designate White Sands
National Monument as a World Heritage Site is triggering

C
Pope Benedict XVI local opposition and fears. Despite the fact that New Mex-
Speaking in Austria, His Holiness decried our ico already has three World Heritage Sites, more than any
growing environmental peril: “Before it is too other state, with no apparent loss of sovereignty, the Otero
late, we need to make courageous choices that will recre- County Commission is condemning this latest brush with
ate a strong alliance between man and Earth. We need a foreign powers. “What if they (the U.N.) decide to close
decisive ‘yes’ to care for creation and a strong commitment it?” wonders Commissioner Nivison. “Do we have a say
to reverse those trends that risk making the situation of in it?...it affects our local custom and culture.” Who knew
decay irreversible.” that xenophobia could be the basis for an entire culture?

10 PEEReview

Wetlands Half-Victory Guarding the Hock
F
ollowing a furious campaign led by
PEER and other groups, the Com-
monwealth of Massachusetts backed
away from the centerpiece of a plan to re-
peal the strongest protections for wetlands
in the country. The proposal by Governor
Deval Patrick for “streamlining” permits
to destroy wetlands has been significantly
scaled back.
In a major victory, planks of the plan to
abolish many citizen appeals and cut pro-
cedural safeguards governing wetland ap-
peals making it harder to protect wetlands
were dropped. The Governor did, how-
ever, eliminate independent review of state
permit decisions, forcing some challengers
to file lawsuits to overturn improper state
permits authorizing wetlands destruction.
In the 1960s, Massachusetts became the
first state in the nation to adopt a wetlands
protection law. It recognizes that wetlands
are the people’s water resources, not just
the developer’s private property. Since Co-
lonial times, nearly a third of the Common-
wealth’s wetlands have been destroyed.
Oops, We Missed
The desalination plant for the Sakon-
net Point Club, a yacht club in Little
Compton, Rhode Island, has more
than a slight problem. The submerged
outfall is not installed at the correct
ocean depth. In order to protect both
human health and an adjacent lob-
ster nursery, the state permit requires
placement in at least 23 feet of wa-
ter to prevent over-concentrations of
nasty, toxic brine. After being notified
by an employee, PEER hired a scuba
diver who found the submerged out-
fall located in eight feet of seawater
at high tide.
The permit allows discharge of up to
3,000 gallons per day, which contains
enough copper, for example, to ex-
ceed three times the lethal dose for an
adult lobster and six times the lethal
level for lobster larvae. PEER is de-
manding that the sleepy state Depart-
ment of Environmental Management
shut the plant and fix the problem.
Fall 2007
Massachusetts
The Massachusetts Bay Transportation Au- remain, and all that is left of the right-of-
thority (MBTA) has promised to re-think way is a flooded dirt path through the vast
its plan to bisect the Hockomock Swamp, forest.
the largest freshwater wetland in Massa-
chusetts, with a train line. The “Hock” is New England PEER Director Kyla Ben-
16,800 acres in size, home to 13 state-listed nett has almost single-handedly de-railed
species, designated as an Area of Critical the train line on the grounds, apart from the
Environmental Concern (ACEC) by the destruction of the Hock, that it would 1)
Commonwealth of Massachusetts, and a add cars on the road rather than removing
priority wetland by the U.S. Environmental them, 2) promote sprawl by linking small
communities, many of which oppose the
Protection Agency.
rail, and ignoring the more heavily popu-
The MBTA proposed commuter rail line to lated routes, and 3) be so uneconomic that
bring people from New Bedford and Fall it would be cheaper to provide individual
River to Boston would have been placed limousines for all of the projected commut-
on an abandoned right-of-way that has not ers than build the rail.
been used by trains since 1960. No tracks
Saving Rattlesnake Hill
New England PEER Direc-
tor Kyla Bennett is locked
in a key development battle
in the Bay State –the re-
zoning of an 87-acre par-
cel known as Rattlesnake
Hill to permit 624 units
of luxury housing in six
eight-story buildings. The
development, proposed by
a national company called
Brickstone, also includes
a 150-bed nursing home,
a number of restaurants, a
four-hole golf course, dry The Balloon Test. This “balloon test” shows how high the
cleaner, hairdresser, and Brickstone buildings will be – tall enough to be seen by
anyone in the vicinity, particularly in the winter.
other amenities.
After the project was approved, Bennett has –
• Uncovered irregularities in the closed-door meetings of the Board of Selectmen
and has filed a complaint with the district attorney;
• Forced a public referendum on the issue;
• Revealed the threat to the groundwater from the proposed septic system for the
complex.
Rattlesnake Hill provides some of the last remaining habitat for several state listed
species. Paving it over would be a huge defeat for state smart growth goals as well
as the state endangered species program. “If we can save Rattlesnake Hill, it will
complete a stretch of more than 2,000 acres of wild lands, a precious treasure in this
part of the country,” Bennett added.
11
 National Oceanic & Atmospheric Administration
Whales Held Hostage
continued from page 1
while rumors of stealth intervention by Vice President Dick
Cheney grow (see sidebar).
In a September 4, 2007, letter to PEER, NOAA Fisheries Direc-
tor William Hogarth, who had testified before Congress in July
that approval was expected within two weeks, admitted that “the
review is ongoing” but offered no new prediction of how much
longer it would take. Nonetheless, Hogarth stressed “collisions
are the primary threat to the recovery of this highly endangered
species.”
At the same time as the U.S. stalls, Canada has moved ahead with
important new protections to prevent further deaths of right whales
from ship strikes by declaring the principal feeding grounds of the
right whale southwest of Nova Scotia off-limits to shipping. The
more than one thousand square mile Roseway Basin has been clas-
sified as an “Area to Be Avoided” from June to December, when
right whales are present.
“In our coastal waters, rare whales are merely speed bumps,”
added Bennett, noting that, following a PEER campaign last year,
the U.S. Coast Guard changed shipping routes on the Eastern Sea-
board to minimize collisions during right whale migrations. “Once
again, the U.S. is forfeiting its leadership on a planetary environ-
mental challenge due to parochial politics.”
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Klamath Fish Kill
continued from page 1
including coho salmon (a federally protected species), died fol-
lowing the abrupt decision to significantly cut in-stream flows.
Caught in the middle was Michael Kelly, a former National Ma-
rine Fisheries Service (NMFS) biologist and PEER client, who led
the Klamath technical team until, in disgust, he asked to be re-
assigned. Kelly recounts being directed to conclude, contrary to
available evidence, that sharply reduced flows would not adversely
affect federally protection salmon. “I was asked to make 1 + 1 =
3,” calling the order both “bizarre” and illegal.
On July 31st, the House Natural Resources Committee held a hear-
ing at which Kelley and top officials, testified. “This is a hearing
that Congress should have held four years ago but, until recently
on Capitol Hill, oversight meant overlook,” stated PEER Execu-
tive Director Jeff Ruch, noting even after the Klamath kill, NMFS
ordered no investigation of what occurred. Instead –
• James Lecky, the NMFS official who directly gave Kelly the
illegal order was promoted to become the agency’s Director
of Protected Resources, overseeing all biological opinions on
threatened and endangered species; and
• A PEER survey found a majority of NMFS scientists saying
they knew of cases in which high-level appointees “inappro-
priately altered” biological determinations.
Kelly, who resigned from NMFS altogether in 2004, recommend-
ed in his testimony that there be an administrative record of any
amendments to scientific documents made by political appointees.
Kelly also called for a criminal investigation into the actions on the
Klamath that killed thousands of protected species. As for Angler,
as usual, he left no paper trail.
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THANK YOU to all the
employees who participated
in the Fall 2006 workplace
giving campaign! PEER will
once again be in this year’s
campaign.
PEER has been honored with the “Best
in America” seal of approval by the
Independent Charities of America.
Federal employees: Just look for PEER in the P section of
the Conservation and Preservation Charities of America in the
Combined Federal Campaign or use designation # 12057 on
your pledge form.
State: We are on the ballot in the following states: CT, FL,
MA, NJ, RI, TX, UT, VA, WA.
Corporate: If your company participates in a workplace giving
campaign, nominate PEER as a charitable organization.

Thank you!
We gratefully thank the Curtis and Edith Munson
Foundation, the Normandie Foundation, the Seattle
Foundation, and Resources Legacy Fund Foundation
for their recent grant support. We would also like to
thank Astrida Apse, Victor and Emma Idell Karlson,
Martin Dreyfuss, Paul Angermeier, and other anonymous
members for their generosity. A big thanks to last year’s
CFC donors!
 PEER books make great holiday gifts

Order Now!
All prices include shipping and handling costs.

Blue Frontier: Saving America’s Living

Seas by David Helvarg is a fascinating account
of America’s oceans and the impact of history,
commerce and policy on marine life--and by
extension all life on earth. Hardcover. Only
$18 for members.
Choosing a Conservation Vocation or
a Bureaucratic Career: Your Personal
Choices and the Environmental
Consequences by Richard Kroger explains
why environmental government agencies
do such a poor job of protecting our public
natural resources and how this malady can
be cured. Only $14 for members.
The Terrorist Next Door: The Militia
Movement and the Radical Right by
Daniel Levitas reveals the men behind far
right groups and the ideas that inspired their
attempts to bring about a racist revolution in
the United States. Only $16 for members.

Beloved of the Sky: Essays and Photographs

on Clearcutting edited by John Ellison takes
the reader to on an essay journey through
clear-cutted ancient forests in the Northwest,
Hawaii, British Columbia and the Grand
Canyon. Only $9 for members.
 The perfect gift for your favorite undercover activist –
socially conscious skivvies!
Symbolic of our work with anonymous public employee
activists, the only PEER apparel is not a T-shirt or a
baseball cap; it’s UNDERWEAR. PEER’s white cotton/
poly blend boxer shorts have the legend “Undercover
Activist” on the rear and the PEER logo silk-screened
on the right leg. PEER boxer shorts are the apparel
undercover activists can wear in the office! Now
available directly from PEER for $15.00/pair, includes
shipping and handling.
Available in Small (waist size 30-32), Medium (34-36), Large (38-40) and X-tra
Large (42-44).
Order Form
Select your purchases on the order list below, fill out the reverse side of this
page, tear it off, and mail it to us in the enclosed envelope. Please include your
check made payable to PEER, or write your Visa or MasterCard number on the
other side. You can also order using Visa and MasterCard via phone at 202-265-
7337 or fax 202-265-4192.
Size Qty. Price Total
Undercover Activist boxers $15.00
Blue Frontier: Saving America’s Living Seas
$18.00
by David Helvarg
Choosing a Conservation Vocation or a
$14.00
Bureaucratic Career by Richard Kroger
Beloved of the Sky: Essays and Photographs
$9.00
on Clearcutting, by various authors
The Terrorist Next Door: The Militia
Movement and the Radical Right, by Daniel $16.00
Levitas
The Art of Anonymous Activism: Serving the
Public While Surviving Public Service by $10.00
PEER, GAP & POGO
All Rise: Somebodies, Nobodies, and the $15.00
Politics of Dignity by Robert Fuller
Membership dues/special contribution

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