"The love for a horse is just as complicated as the love for another human being... If you never love a horse, you will never understand."
~ Author Unknown
Wild Earth Guardians (Report on fiscal costs of public lands grazing in the American West & other resources on public lands management and suggested actions to take) www.sagebrushsea.org
Here we go again, folks. The BLM is clearly in contempt of court and we have another chance to prove it. Please help support Laura! The only place you can donate to Laura Leigh's legal fund is at www.grassrootshorse.com.
RENO, Nevada – On July 30th
Laura Leigh re-filed Contempt of Court charges against Ken Salazar, Secretary ofthe Department of the Interior, Bob Abbey, Director of the BLM and Ron Wenker, Nevada State Director of the BLM in regard to what BLM calls the “Tuscarora wild horse gather.” The BLM continually refers to the three herd management areas of Owyhee, Rock Creek and Little Humboldt under one umbrella name of Tuscarora. Thejudge, at the time of hearing earlier motions, recognized that Tuscarora was
three herds and not one as BLM would like people to believe.
Adding to what seems like a deliberate move to create confusion, every day the gather schedules change. At present the BLM website, touted in BLM press releases as the only place for correct information, has two completely different gather schedules posted. If a person really wants to know the true schedule they have to contact the appropriatefield offices. It would seem to even the casual observer to be a shell game of now you see it, now you don’t.
The judge denied the original motion to hear the case based on the parameters set forth in a statute known as the Winters standard. This is the standard by which actions seeking injunctive relief are judged on their merit. On July 28, 2010, the Ninth Circuit Court of Appeals modified its position on the test used to determine the element, “likelihood of success on the merits” when granting or denying injunctive relief under the Winters decision. The circuit court reaffirmed the use of its sliding scale method, finding it consistent with Winters.
The law change opened the door for the re-filing under the new guidelines. “We are not going away,” said Laura Leigh, plaintiff in the lawsuit brought about through the support of Grass Roots Horse, a citizen action group. Support for Laura Leigh’s court action is coming in from people all over the country. “Some people are donating to further the cause with $3.00 donations,” said Maureen VanDerStad, member of Grass Roots Horse. “That tells it all right there. People are so fed up with the mismanagement of the wild horses and burros that they want to be a part of doing something to stop it. The blatant disregard for our First Amendment rights by BLM and the cruel and inhumane treatment of the wild horses, which belong to the American people, has spurred the movement on with a vengeance,” she further states.
Laura Leigh is an artist, author and journalist who is best known for her work in documenting wild horses. She is the founder and director of Herd Watch, a citizen group that monitors the actions of the BLM and the Wild Horse and Burro Program. Full reports documenting range conditions in herd management areas and the condition of the horses themselves are conducted by Herd Watch with a
meticulous eye for detail.
Yesterday at the Nevada State Legislative meeting, the main focus was on the implications of the Western Watershed Organization’s multi-million dollar settlement with Ruby Corporaton, representing Ruby Pipeline. The Wild Horse and Burro Program came into the discussion and Laura Leigh was there to set the record straight. “Sitting in the audience it was really interesting to see the cattlemen bringing up the very same issues of the difficulties of dealing with the BLM that the wild horse advocates have been dealing with for years. If people do not support accountability in government, it is easy to see how that failure to demand accountability and transparency can turn against them,” Laura Leigh said.
To read the legal filings, donate to the legal fund, or volunteer please visit www.grassrootshorse.com where there are links to the best sites with more information on the issue.
The BLM is totally out of control, killing and brutalizing the Mustangs they are supposed to protect. They spin their way out from under the law, doing only the bidding of Big Cattle and Big Energy.
The Bureau of Land Management is the federal agency within the Department of Interior that is tasked with protecting wild horses and burros.
But someone needs to tell the BLM that.
The Wild Free Roaming Horses and Burros Act is specific in requiring BLM to protect wild horses and burros as "components" of the public lands, free from "harassment" and "capture," and manage them at the "minimal feasible level" to maintain "free -roaming" behavior. Instead, BLM has turned the Act on its head, managing these animals primarily by rounding them up and placing them in long term holding facilities.
Two federal judges have already warned BLM that its policy of keeping wild horses and burros in long term holding facilities may not be legal.
This past week, Laura Leigh filed a lawsuit in Nevada federal court asking Judge Larry Hicks to order BLM to delay the Tuscarora roundup until after foaling season, and also to allow media access to the roundup.
In January 2008, when the BLM Winnemucca Field Office approved the new grazing proposal for the Soldier Meadows Allotment, Western Watersheds Projectfiled an appeal and took BLM to court to challenge that decision.
As a result, extensive testimony from BLM personnel has been given about the Soldier Meadows Allotment and is now part of the public record, some of which included testimony from Glenna Eckel, BLMs Winnemucca Wild Horse & Burro Specialist on May 13th, 2009.
Ms. Eckel testified, under oath, in a court of law, about impacts from wild horses on the range in areas of the Calico Complex that she had been monitoring for the last six years. Below are some of the highlights of this testimony. To view the complete transcript, Click Here.
Page 818
Line 20, Answer from Eckel; “I’ve been assigned the Warm Springs Canyon Herd Management Area and the Calico Mountains Herd Management Area for the last six years. I have only been assigned to the Black Rock Range West for the last year.”
Page 796
Line 18, Answer from Eckel; “Well, I guess, honestly, I’m surprised that the number of horses that are out there, based on my monitoring data that I’ve done the last couple of years, that the monitoring data hasn’t shown a higher utilization than what I’ve read. So I guess what I am thinking is that I’m not sure it would change my conclusion.”
Line 24. Question; “Increasing the horses five times would not change your conclusion; is that right?”
Page 797
Line 1, Answer from Eckel; “Well, I think, again it boils down to that competition. And what I have seen, again based on the monitoring data, is that I would have expected different monitoring data than what I’ve collected, based on those numbers.”
Page 809
Line 22, Question; “Okay. I believe, in your testimony, you made a statement that you were surprised at the number of horses that were out there, that the monitoring data hasn’t shown higher utilizations than what you read?”
Page 810
Line 1, Answer from Eckel; “Correct”.
Line 2, Question; “Could you just elaborate a little bit more on what you meant by that?”
Line 4-16, Answer from Eckel; “Sure. I guess what I mean is, given the March ’08 census and the numbers we counted, I didn’t have that knowledge prior to March ’08. So the monitoring that I did and since the last gather, which was in 2004-2005, I was under the impression that we were at AML, those population estimates that we looked at earlier.”
“And what surprises me is that now, knowing that we had – I can’t remember what you gave it, a certain percentage over. But there’s significantly more animals out there than what we thought were, so I would have expected the monitoring data to show higher levels of use than what I collected. And I guess I’m learning it’s a big country, animals move”.
Page 814
Line 18-21, Question; “What were the implications, in your mind, of the monitoring data that you collected? In other words, once you gathered it, what were your – perhaps “conclusions” is a better word.”
Line 25, Answer from Eckel; “And at the time, again, like after the gather, I assumed that we were close to those population estimates of being under AML, and so the monitoring data was meeting management objectives that we had identified. And again, I was thinking we had a smaller population than I learned then in 2008.” (emphasis added).
To summarize, Glenna Eckle stated that, despite wild horse populations being five times over BLMs “established AMLs” in the areas she was monitoring in the Calico Complex, BLMs “monitoring objectives were being met”, that this significantly larger population was NOT evident in their forage consumption, that she had no idea they were so far over AML until they flew over the area and counted the horses, and that based on what she had seen, she was really surprised about what she was finding on the range regarding wild horse impacts.
To understand the full legal implication of what Glenna is saying here, it is also important to understand what the courts have already told BLM in the past about the legal criteria they must use to determine what is “excess” before they have any authority to remove wild horses and burros from the range.
“The test as to appropriate wild horse population levels is whether such levels will achieve and maintain a thriving ecological balance on the public lands. Nowhere in the law or regulations is the BLM required to maintain any specific number of animals or to maintain populations in the number of animals existing at any particular time Dahl v. Clark, supra, at 595. A determination that removal is warranted must be based on research and analysis, and on monitoring programs, which include studies of grazing utilization, trends in range conditions, actual use, and climactic factors". Michael Blake, supra: Animal Protection Institute of America 109 IBLA 112, 120 (1989); see Craig C. Downer, 111 IBLA 339 (1989)
The Calico Complex Environmental Assessments never mentioned Glenna’s testimony or what she found about “monitoring objectives being met” with five times the wild horses than BLM knew were out there before they counted them.
Instead, BLM buried the evidence and used old decisions to perpetuate the “Appropriate Management Levels” of wild horses in the area, some of which were set as far back as 1982.
So now, wild horses are galloping in the snow, down steep terrain, through rocky, icy, slippery paths on private land and being hauled to BLMs newly built Northern Nevada wild horse holding facility, not the publicly open Palomino Valley Facility, but a facility so new, BLM doesn’t even have a protocol established for public access yet.
There’s been a lot of speculation flying around the Internet the last few days about “why” the Calico Complex wild horses are being shipped to this facility instead of the publicly accessible Palomino Valley.
One source familiar with the Calico wild horses stated they were prone to strangles. This is being confirmed from another source that stated they have been communicating with BLM's John Neil, the man in charge of both the Palomino Valley Holding Facility as well as the newest one the Calico Complex wild horses are being shipped to. According to this source, John Neil stated, "Some of the horses coming in off the Calico Mountain Complex, particularly from the Warm Springs area, have contagious upper respiratory issues. As a result they are all being transported to BLM's new contract holding facility in Fallon."
According to a January 31, 2006 article in LA Weekly, Mustang author Deanne Stillmanstated, “...46 wild horses at the BLM corral in Susanville, California, have died of strangles, an upper respiratory infection that can kick in after a horse is stressed — or after, for instance, being run too hard during a helicopter roundup.”
In Animal Welfare Institutes “Managing for Extinction”, a publication regarding critical issues found in BLMs management of the Wild Horse & Burro Program that continue to stay unresolved, it appears the issue of strangles is not isolated to just the Calico wild horses, as AWI has also reported:
“In the fall of 2006, the Palomino Valley, NV and Litchfield, CA holding facilities suffered from outbreaks of strangles, a highly infectious and serious respiratory disease. During the past two years, practically every BLM facility has experienced similar disease outbreaks, leading to the confirmed deaths of scores of animals…..”
While BLM points to wild horses being “prone to strangles” as the reason for their isolation and why it is important to keep them far from the public eye, (and we can only wonder why BLM would want to expose approximately 2,500 wild horses to each other that are now at risk of catching strangles from their new exposure to each other), perhaps BLM should begin to reconsider their decisions to manage wild horses by running them in the winter, in the snow, like they did to Jewel, the beautiful wild mare that was run down on December 13th, 2007 during BLMs round up of the Antelope and Antelope Valley Herd Management Areas in Nevada.
A wild stallion on the Pine Nut Range in Northern Nevada
photo by Carrol Abel
Was last years Bureau of Land Management announcement of plans to euthanize 33,000 wild horses a prelude to the BLM program's swan song? A clamor of voices rapidly growing in number has brought the wild horse and burro program under the spotlight of mainstream press. Conducting business as usual is no longer acceptable to the American public.
The BLM has been operating the program with an omnipotent mind set for so many years they can't seem to function otherwise. Evidence that detail of program policies will not hold up under scrutiny is popping up from all directions. Can it stand the final test of President Obama's promise of transparency in government.
There seems to be little connection between the left and right hands of upper management. Don Glenn, head of the national program, stated to this examiner, "Wild horses are not starving. The press repeatedly gets that wrong. We don't know of any that are starving right now. The range is in good condition." Apparently, Glenn did not communicate that to his boss, Department of Interior Secretary Ken Salazar.
"One of the first things he said was something must be done because the horses are starving." said singer Sheryl Crow of her conversation with Salazar in a recent interview with AP reporter Martin Griffith.
The Surprise Field Office recently conducted an unscheduled removal of over 200 wild horses near the Nevada/ California border giving advocates no opportunity for legal filing to stop the action. Apparently, Glenn was not aware. Either Glenn is hiding the truth or management has no idea what the field offices are doing. Any way one chooses to look at it, this makes a huge statement.
Even Department of Justice lawyers seem to be tripping over their tongues. Erick Petersen defended BLM's position in a district court hearing to determine the merits of a request for injunction to stop the Calico Complex roundup. "Removing the animals also will help preserve the endangered and rapidly disappearing rangeland where they live." Petersen said. Maybe Glenn didn't tell him "The range is in good condition."
Petersen also said "The 1971 law requires removal of excess horses to ensure they are treated humanely." He was joking wasn't he?
Animal welfare groups have been frustrated with BLM contradictions and inconsistencies for some time. The program istelf would seem to be a contradiction.
District Court Judge Rosemary M Collyer ruled against a Colorado roundup in August of this year saying,
"It would be anomalous to infer that by authorizing the custodian of the wild free roaming horses to 'manage' them, Congress intended to permit the animals' custodian to subvert the primary policy of the statute by capturing and removing from the wild the very animals that Congress sought to protect from being captured and removed from the wild."
Celebrities, scientists, Animal welfare and Wild Horse Advocate organizations along with private citizens are supported by members of Congress in their call for an immediate moratorium on wild horse roundups pending Congressional investigation. And yet the roundups continue at an escalated pace. By all appearances, it's a last ditch attempt at the annihilation of America's wild horse herds.
A call is growing to remove the wild horse and burro program from the BLM altogether..... a movement also supported by some members of congress.
In all fairness to Ken Salazar, he has been on the job for less than a year. He inherited the problem. Corralling the BLM herd of management dinosaurs in that period of time is an unrealistic expectation. A anonymous source stated to this examiner," This is a timely moment. For the first time in history, this has gotten the Secretary's attention." The statement is pleasant to the ears. But the questions remain. Can Ken Salazar bring the program into the 21st century? Will the program be removed from the BLM before America's symbol of freedom is no longer free?
How the US Government is eradicating an American icon
Over the past 30 years, under pressure from special interest groups and in blatant disregard of the public’s wishes, the BLM has systematically favored subsidized livestock grazing on public lands to the detriment of wild horse populations. The Burns Amendment, slipped into the 2005 federal budget without so much as a hearing or opportunity for public review, was the last nail in the coffin of federal wild horse protection, opening the door to the slaughter of thousands of these living symbols of our Nation’s spirit. A few months later, while in the process of rounding up another 10,000 horses supposedly due to poor range conditions, BLM eased public land grazing restrictions for private cattle. Now BLM is considering simply killing "excess" horses to help balance its budget.
In 1971, the Bureau of Land Management (BLM), an agency of the U.S. Department of Interior, was put in charge of implementing the Wild Free-Roaming Horse and Burro Act. When the Act was passed, the U.S. Senate stated: "An intensive management program of breeding, branding, and physical care would destroy the very concept that this legislation seeks to preserve […], leaving the animals alone to fend for themselves and placing primary emphasis on protecting the animals from continued slaughter and harassment by man." Sadly, this Congressional mandate has been ignored and, over the past thirty-five years, no strategic plan to keep viable herds of wild horses on public lands was ever developed.
Pursuant to the 1971 Act, BLM is directed to protect and manage wild free-roaming horses and burros as components of the public lands, and may designate and maintain specific ranges on public lands as sanctuaries for their protection and preservation. Yet, its management policy has translated into a diligent and steady herd reduction campaign, causing America’s wild horse population to dwindle to less than 25,000 and to lose 19 million acres of its legally allocated range. Approximately 36,000 wild horses and burros adopted through BLM’s Adopt-A-Horse program are unaccounted for, and in 1997, BLM’s Wild Horse and Burro Program Director conceded that about ninety percent of rounded up horses ended up at slaughter. Questioned off-the-record, BLM employees routinely acknowledge rampant mismanagement and disregard for the 1971 Act (see Case Study #1).
In 1992, wild horses and burros were left out of BLM’s revised mission statement altogether.
“Excess Animals”: A Very Nebulous Concept
The 1971 Act requires that wild horses "be considered in the area where presently found, as an integral part of the natural system of the public lands." The Act also defines "range" as “the amount of land necessary to sustain an existing herd or herds of wild free-roaming horses and burros, which does not exceed their known territorial limits, and which is devoted principally but not necessarily exclusively to their welfare, in keeping with the multiple-use management concept for public lands." By law, only “excess animals” should be removed from the range. It is therefore how BLM determines “excess” that will shape the entire Wild Horse and Burro Program.
The legal requirement that “excess” be determined based on population monitoring and inventory has been circumvented by allowing BLM to determine “excess” based on whatever information is in its possession at the time a decision is made, rather than requiring that relevant information (such as actual census numbers) be obtained. In fact, only four percent of BLM’s wild horse and burro budget is allocated to population inventory. The legal requirement that BLM consider the “recommendations of qualified scientists in the field of biology and ecology, some of whom shall be independent of both Federal and State agencies,” has also been circumvented or ignored.
“Excess” is simply determined on paper, using grossly inflated fertility rates (up to 25%, whereas the National Academy of Sciences estimates actual growth rates to be closer to 10%) and generalized data that does not take into account the specificity of each geographic area (foaling rates, mortality rates and foal survival rates can vary greatly from one area to the next). This questionable methodology leads to highly inaccurate population estimates (e.g. an 800% discrepancy in the Salt Wells HMA - WY, 2006).
In conjunction with flawed population monitoring, BLM relies on the notion of “Appropriate Management Level” (AML) to determine “excess.” AMLs dictate how many horses and burros can be allowed on the range, and therefore what constitutes “excess.” AMLs are the single most important tool in BLM’s arsenal. They are also a moving target: once AML is reached in an area, meaning the wild horse population is deemed at an acceptable level, it is often subsequently lowered, paving the way for more round-ups (e.g. in 2001, the national wild horse AML was drastically lowered to 26,000; since then, it has crept down by a few hundred every year, adding up to a further loss of 1,500 as of 2006).
AML for a given Herd Management Area (HMA) is based on forage and water availability, or rather, forage and water allocation. Case study after case study have shown that BLM consistently allocates substantially more forage to private livestock and game animals on the very areas that were legally designated for wild horses (e.g. 700% more forage allocated to livestock than to horses in the Stone Cabin Complex - NV, 2007), steadily reducing wild horse AMLs, sometimes to the point of eradication (the so-called “zeroing out” of a herd area).
Likewise, only a small fraction of water available in a given area will be allocated to wild horses (e.g. 7% in the Spring Mountain Complex - NV, 2006), who will then be removed due to supposed lack of water, while livestock and game animals are allowed to thrive in areas that, by law, were to be “devoted principally” to wild horses (see Case Study #2). Case in point: bighorn sheep can be found on seventy-five percent of Nevada’s Muddy Mountain HMA and are allocated water from the National Park Service (NPS), water guzzlers and specially made dams. These water developments have allowed the HMA to be turned from seasonal into year-round bighorn habitat, a victory for the local hunting lobby, but are not taken into account in determining wild horse and burro AMLs for the area, despite a federal mandate that “all range improvements […] be installed, used, maintained and/or modified on public lands […] in a manner consistent with multiple-use application” (43 CFR 4120.3-1 (A)).
Another critical piece of federal regulation states: “If necessary to provide habitat for wild horses or burros, to implement herd management actions, or to protect wild horses or burros from disease, harassment or injury, the authorized officer may close appropriate areas of the public lands to grazing use by all or a particular kind of livestock.” (43 CFR 4710.5 (A)) This provision is also routinely ignored.
More Round-Ups
Round-ups (or “gathers,” to use a placating BLM euphemism), are BLM’s “management” tool of choice: the fewer horses on public lands, the more convenient for public land managers and special interest groups. Oftentimes, livestock is restocked shortly after wild horses have been removed (e.g. about 1,000 sheep reportedly brought in the Dry Lake Complex just a couple of weeks after 200 horses had been removed from that same area - NV, 2006; ten-year grazing permit granted for 6,882 head of cattle in New Pass Ravenswood HMA the same month as 692 horses are removed from the same HMA due to "lack of forage" - NV, Oct. 2007).
In addition to the concept of “excess animals,” BLM has several tools at its disposal to justify round-ups. Early on, BLM did not capture wild horses who ranged out of their herd boundaries. Today, if wild horses step out of their boundaries, BLM removes them permanently from public lands. In the state of Nevada, home to about seventy percent of our nation’s wild herds, horses found outside of their federal boundaries are treated as stray animals and sold at auction, usually ending up at slaughter.
Another well-established BLM practice is to thin out herds to the point where they are no longer deemed genetically viable, and then use the threat of in-breeding as an excuse to zero out such herds completely. It has been estimated that up to three-fourths of our remaining wild horse and burro herds are below population levels that would guarantee their long-term survival. Sex ratios in wild horse herds normally average 50/50. To further affect viability, BLM will stack herds with seventy percent of males, severely disrupting herd dynamics and behavioral patterns. Still, BLM’s most often used rationale for round-ups is the threat of starvation and drought conditions: so-called “emergency gathers” are another way for BLM to circumvent the legal requirement that only “excess” animals be rounded up.
Whereas private cattle and sheep are promptly restocked, if in fact they were removed at all (e.g. almost 50% of the total estimated horse population removed from the Ely District following brush fires, but no reduction in authorized livestock for the 23 affected grazing allotments - NV, 2006), horses are not returned to the area after the “emergency” conditions subside. BLM simply makes the zeroing out of the HMA official by issuing an AML of zero: a wild horse range originally managed under the Wild Free-Roaming Horse and Burro Act is now permanently devoid of wild horses (e.g. Blue Nose Peak HMA, AML of 1 - NV, 2003). Over the years, dozens of HMAs, representing millions of acres, have met this fate.
“This is not a Democracy” (Jim Sparks, BLM District Manager, at a Sept. 2008 public hearing in Billings, MT)
A 1990 GAO report found that “in many areas where wild horse removals have taken place, BLM authorized livestock grazing levels have either not been reduced or have been increased thereby largely negating any reduction in forage consumption.” In 1997, Public Employees for Environmental Responsibility noted that “little has changed since the 1990 GAO report. Wild horse management decisions continue to be made within the BLM on a political rather than scientific basis, and in the political balance between horse and cow, the cattle industry almost always wins.” (see Case Study #3)
This happened during the Bush Administration - but, why hasn't anything been done to correct the situation? Please, contact your Senators and Representatives and ask them.
Grazing Regulations Include Doctored Environmental Analysis
Bureau of Land Management (BLM) officials compromised the integrity of a BLM study by removing scientific concerns about the effects newly relaxed grazing regulations would have on public lands. Millions of acres of public land in the western U. S. are protected by BLM grazing rules, which regulate when, where, and for how long cattle may graze there.
Julie Cart of the Los Angeles Times reported that prior to relaxing Clinton-era restrictions on cattle grazing in June 2004, the BLM edited out portions of an environmental analysis calling into question the environmental sustainability of the new regulations.1 Agency scientists had studied the effects of grazing on wildlife and water quality and expressed concerns.
Cart reported that the BLM eliminated the original draft's warning that the "the Proposed Action will have a slow, long-term adverse impact on wildlife and biological diversity in general." Instead, the final version of the environmental analysis endorsed the new regulations, which were supported by the cattle industry, stating that the new rules would prove "beneficial to animals."2
Erick Campbell and Bill Brookes are both recently retired scientists, each with more than 30 years experience at the BLM. Campbell, a biologist, authored the section of the BLM study on the impacts of the rule change on wildlife and endangered species, while Brookes, a hydrologist, evaluated the impact on water resources. Both characterized the edits as an attempt to suppress scientific information. Campbell termed the matter "a whitewash" and "a crime." "They took all of our science and reversed it 180 degrees," he said. Brookes agreed, adding "Everything I wrote was totally rewritten and watered down."3
The BLM argued that the changes resulted from a standard editorial process and issued a statement saying the conclusions reached by Campbell and Brookes were "based on personal opinion and unsubstantiated assertions rather than sound environmental analysis."4 In an interview Campbell refuted those charges, saying "All the science they extracted from my narrative was peer-reviewed science. This was not gray literature...This was peer-reviewed science in major journals."5 The concerns of Campbell and Brookes were echoed by wildlife experts at the U. S. Fish and Wildlife Service and by officials at the Environmental Protection Agency.6
1. Cart, Julie. "Land Study on Grazing Denounced." Los Angeles Times, June 18, 2005. latimes.com requires subscription, article available from advocacy website, accessed December 5, 2006.
2. Bureau of Land Management, "Grazing Administration--Exclusive of Alaska; Final Rule," Department of the Interior, July 12, 2006, accessed December 5, 2006.
3. Cart.
4. Bearden, Tom. "New Grazing Rules." NewsHour with JimLehrer, August 10, 2005. Transcript online, accessed December 5, 2006.
5. Mitchell, Michele and Breslauer, Brenda. NOW with David Brancaccio, July 22, 2005. Transcript online, accessed December 5, 2006.
6. Cart, Julie. "Federal Officials Echoed Grazing-Rule Warnings." Los Angeles Times, July 17, 2005. latimes.com requires subscription, available online from advocacy site, accessed December 5, 2006.
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