(Edit and Copy this letter — sent to DOI as addressed and to Your Legislator/Representative — getting the word out about a corrupt government agency is important)

Office of the Executive Secretariat and Regulatory Affairs:
U.S. Department of Interior
1849 C Street, NW
Washington, DC 20240

Complaint of Scientific and Scholarly Misconduct

The DOI Policy for the Integrity of Scientific and Scholarly Activities posits its central policy as:

§ 3.4 Policy “The Department… will not tolerate loss of integrity in the performance of scientific and scholarly activities or in the application of science and scholarship in decision making…”

As detailed above, Bureau of Land Management (BLM) staff and Department of the Interior (DOI) staff has set aside recovery criteria and designation of suitable habitat based upon the best available science in favor of what is termed, Welfare Ranchers who acquired preferential grazing permits on Public Lands.

Further, BLM and DOI allowed:

a. the politics of Cattlemen Lobby Group to suggest and make decisions contrary to proper Wild Horse and range management;
b. Current Director of the Department of the Interior and oversees the BLM and the Wild Horse and Burro Program – questionable Ethical Conflict and more, who has many Rancher friends, maintains blatantly bias principles and ideologies against America’s Wild Horse Herds;
c. the Wild Horse and Burro Program’s Consultants, who are all Ranchers and horse breeders and selected to the Consulting Board due to their bias “Same Objective” ideology, which unethically dictates what positive criteria or habitat could be considered for America’s Wild Horse Herds.

In short, America’s Wild Horse Herds management ideology and principles’ has become the antithesis of scientific integrity.

Public Venting

The policy further requires that scientific findings and conclusions be made subject to public vetting:

§ 3.4.C “ Document the scientific and scholarly findings considered in decision making and ensure public access to that information and supporting data through established Departmental and Bureau procedures…”

In this instance, Environmental Assessment documents were leaked to politicians and selected lobby groups and other friends of BLM and DOI staff and other groups. By contrast, the deliberations between BLM, DOI, WH&B Consultants, Welfare Ranchers, other groups and state agencies in the SDM process were kept behind closed door, with no public access to the scientific data, conclusions or the standard by which decisions were being made.

The DOI rules define misconduct to include:

§3.5(M)(1) “Misconduct also includes: (a) intentionally circumventing policy that ensures the integrity of science and scholarship, and (b) actions that compromise scientific and scholarly integrity.”

§3.5(M)(3) “A finding of scientific and scholarly misconduct requires that:

(a) There be a significant departure from accepted practices of the relevant scientific and scholarly community.

(b) The misconduct be committed intentionally, knowingly, or recklessly.
(c) The allegation be proven by a preponderance of evidence.

In this instance, all actions by subjects of this complaint appear to be intentional rather than the product of mistake or confusion. The intricate interference denotes an acute awareness by the actors of the consequences of their actions with respect to what steps would be taken in current Wild Horse Herd Management and circumventing Ecosystem adjustments appropriately.

As detailed above, the work product of scientific experts reflecting both their collective judgment applying the accepted practices of the scientific community was variously set aside, delayed, skewed or manipulated into irrelevance by the actions detailed above. As a result, the ESA and even TAYLOR GRAZING ACT / FLPMA / NEPA mandates that ecosystem management and recovery planning be based upon best available science was set aside.

The downward adjustment of recovery criteria and the exclusion of suitable habitat on the basis of political and other socioeconomic factors represent significant departures from accepted practices of the relevant scientific and scholarly community. In short, the end result of the NEPA or EA process was, and throughout the years, meant to reach a politically acceptable pre-determined result regardless of the science.

Finally, this complaint is supported by more than a preponderance of the evidence. Further, we know of no information which contradicts this narrative of events.

Conclusion: The purpose of the DOI Policy for the Integrity of Scientific and Scholarly Activities is to prevent political manipulation of science in precisely the manner in which it has occurred in the case of Wild Horse Herd Management planning as outlined in this complaint. We urge that you undertake an investigation of this matter immediately.

We have a number of supporting documents and suggested witnesses to the events described above and we will provide you that list under separate cover should this complaint be accepted for investigation. If you desire any clarification of the above or additional information, please do not hesitate to contact me.

Respectfully Submitted,

John W. Cox
Horse Advocate / American Veteran