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Showing posts from May, 2020

NEPA Violations by USFWS Exposed - Arctic National Wildlife Refuge

Excerpt from Objection to ANWR Pack Llama by Scott Woodruff (Lander Llamas) Thank you for this one and only meaningful opportunity to publicly comment on the prohibition of pack llamas on our public land in the Arctic National Wildlife Refuge (ANWR) based upon the threat of disease transfer to wildlife. Specifically, the proposed regulation change to 50 CFR part 36 published in the Federal Register on April 9th, 2020 with relationship to cited justification in the 2015 Record of Decision (ROD) for the Arctic National Wildlife Refuge Revised Comprehensive Conservation Plan (CCP), and also new and recent submitted information and research outside of the ROD in 2015, by USFWS and ANWR. In 2010, the ANWR sent out a notice of intent to revise the 1988 Arctic National Wildlife Refuge Comprehensive Conservation Plan (1988-CCP). The subsequent public development of the new document Artic Refuge Draft Revised Comprehensive Conservation Plan (DCCP) was submitted for comments. In the D

Precautionary Principle and Pack Llamas

The "precautionary principle" originated as a strategy to deal with possible risks where scientific understanding/study was not yet complete (i.e. nano technology and genetically modified foods.) However, the precautionary principle (precautionary approach) has also been used by policy makers to justify discretionary decisions in situations where there is a possibility of harm from making a certain decision when they deem there is inadequate scientific knowledge. Why Should I Care? The danger is that a precautionary (no risk) principle/approach fails to recognize there is no such thing as zero risk. For example, a scientific risk assessment recognizes the existence of "risk" and attempts to quantify it. The objective is to determine the likelihood of something happening and the consequences. Although science can provide a high level of confidence it can never provide absolute certainty. The precautionary principle places an impossible burden of proof on the us