Archived White Papers

PEER White Papers are anonymous reports written and reviewed by public employees explaining resource issues or exposing agency malfeasance. Each PEER White Paper is available below as a PDF file.

Army Corps of Engineers

Count on the Corps — An Environmental Profile of the Army Corps of Engineers Alaska District (April 1999)
Purporting to regulate and develop responsibly, the Alaska District of the Army Corps of Engineers has violated the Clean Water Act by circumnavigating or breaking its own codes. With seven years of documented cases, such negligence in America’s “Last Frontier” has caused environmental destruction, wasted public funds, and ruined careers of responsible public professionals. more >>

Rotten at the CorpsThe U.S. Army Corps of Engineers Presiding Over the Death of the Florida Keys (January 1997)
The Army Corps of Engineers is presiding over ecosystem destruction in the Florida Keys through a systematic and deliberate dereliction of duty in protecting wetlands from illegal development. more >>

Bureau of Land Management

Horses to SlaughterAnatomy of a Coverup within the BLM (April 1997)
The Bureau of Land Management (BLM) within the Department of Interior is the agency mandated by law “to protect and manage wild free-roaming horses…as components of the public lands.” Yet, the BLM has tolerated and in some instances facilitated the routine and illegal trafficking of wild horses to slaughter. The agency has obstructed efforts by its own law enforcement officers to expose commercial theft of wild horses, fraudulent adoption schemes and fictitious “sanctuary” herds not only to avoid embarrassment but also to maintain the flow of horses off the range. more >>

Land of No ReturnsBankruptcy of the BLM Public Domain Forestry Program (April 1997)
An 18-month investigation of the Bureau of Land Management’s (BLM) Public Domain forestry program by Public Employees for Environmental Responsibility (PEER) reveals that nearly all BLM districts lose money on their timber sale programs. Monetary losses from the BLM’s forestry program are roughly equal to the agency’s entire forest management budget. Based on current and projected future budget allocations, the program stands to lose more than $30 million over the next five years. more >>

Bureau of Land MismanagementTimber Sale Maladministration (March 1997)
Through negligence and outright fraud, nearly half of the timber harvested from the public domain is stolen. BLM’s “lump sum” removal techniques result in timber purchasers regularly taking more trees than allowed, in some cases five times the contract volume without additional payment. more >>

Never Mind NEPANo Laws, No Science, No Problem for the BLM (December 1996)
BLM fails to comply with federal laws when conducting timber sales. The agency’s preoccupation with “getting the cut out” violates environmental safeguards and precludes public oversight. more >>

Savage SalvageThe Timber Feeding Frenzy within BLM, Part Three of a Comprehensive Study of the Forestry Program of the Bureau of Land Management (September 1996)
Poor timber sales practices by BLM are aggravating wildlife potential in the West and cutting into healthy forests at an unsustainable rate. A “salvage rider” has allowed prime, young trees to be sold as salvage, while dead or diseased trees are left on site. BLM has allowed harvests to continue at alarming rates. In 1996 BLM gave California, Montana, Washington, and Oregon permission to exceed their sustainable harvest rates by 500%. more >>

Where Timber Beasts Rule the EarthOvercutting BLM Public Domain Forests (July 1996)
The BLM destroys fragile, transitional public domain forests through over cutting. The agency fails to harvest timber in a sustainable manner, using erroneous data and exceeding maximum allowable cut levels. more >>

Phantom ForestsPart One of a Comprehensive Study of the BLM’s Forestry Program (May 1996)
BLM forest inventories and plans are outdated, inaccurate and incomplete despite agency policy. The agency vastly exaggerates the success of reforestation efforts and counts barren tracts as fully restored. more >>

Public Trust BetrayedEmployee Critique of Bureau of Land Management Rangeland Management (January 1995)
The Bureau of Land Management (BLM) within the Department of Interior manages livestock grazing for the economic benefit of private permittees across 245 million acres of its land holdings in the American west. In this White Paper, BLM’s own scientists charge the agency with gross mismanagement resulting from rampant catering to industry interests, leading to the ecological deterioration of millions of acres of rangeland. more >>

Department of Interior

Tortoise on the Half-ShellEnvironmental Malpractice at Mojave National Preserve (November 1999)
Details an inside account about how a federal agency legally dedicated to conservation has abdicated its responsibilities to the direct detriment of the natural resources and wildlife in its care. As a consequence of political presure and bureaucratic inertia, legal mandates have been flaunted, critical scientific data ignored and park managers have taken the posture that grazing at Mojave NP is, and will likely remain, unmonitored, unregulated and untouchable. more >>

War of AttritionSabotage of the Endangered Series Act by the U.S. Department of Interior (December 1997)
The U.S. Department of the Interior consistently ignores its own scientists’ recommendations to list species as threatened or endangered under the Endangered Species Act (ESA). To stall discussion and shift the burden, the Department of the Interior is waiting for Congressional approval for a reauthorization bill that would greatly weaken the act. more >>

Department of Justice

Uneven JusticeEnvironmental Prosecutions in the Clinton Administration and U.S. Attorney Environmental Report Card (December 1998)
According to an analysis of federal records, prosecution of environmental crimes has sharply fallen during the Clinton Administration. Comparing statistics from a three year period in the Bush Administration (1989-91) with a similar period in the Clinton Administration (1994-96; the last years for which data is available), this review shows dramatic declines in criminal referrals, prosecutions and convictions. more >>

Blueprint for Reform of Environmental Prosecutions at DOJAgenda for the Assistant Attorney General of Environment and Natural Resources (June 1994)
Environmental Enforcement professionals within the Department of Justice (DOJ) and the Environmental protection Agency (EPA) are concerned about the lack of new direction within the Environment and Natural Resources Division (ENRD), particularly the Environmental Crimes Section (ECS). Law Enforcement professionals have decided to speak out collectively via this blueprint for reform of the ECS. more >>

Environmental Protection Agency

Trading Thin AirEPA’s Plan to Allow Open Market Trading of Air Pollution Credits (June 2000)
This report details the problems plaguing EPA plans for open market trading of air pollution credits and explains their consequences for public health and the environment. more >>

Murky WatersAn Inside Look at EPA’s Implementation of the Clean Water Act (May 1999)
An inside look at EPA’s implementation of the Clean Water Act. This report contains a set of recommendations to remedy the deficiencies in the water quailty assesment for our nation’s rivers and streams. more >>

Genetic GenieThe Premature Commercial Release of Genetically Engineered Bacteria (August 1995)
The EPA is preparing to approve the first commercial release of genetically engineered bacteria for use in agriculture. EPA scientists charge that the agency has not adequately assessed the environmental or human health risks of releasing this new life form into the environment. more >>

Fish and Wildlife Service

Swan DiveTrumpeter Swan Restoration Trumped by Politics (August 2001)
Swan Dive traces how the declining prospects for the survival of Greater Yellowstone’s trumpeter swans have intertwined with decisions by the agencies charged with ensuring their survival. Unfortunatley, these decisions have imperiled this last native nesting population of trumpeters in the lower 48 states. more >>

Sitting DucksUSFWS Assaults the Migratory Bird Treaty Act (June 1998)
According to its own law enforcement personnel, the U.S. Fish & Wildlife Service is bowing to intense political pressure to allow unethical hunting techniques, principally baiting, which they believe will facilitate detrimental over-harvesting of migratory game birds. The Special Agents are outraged by what they see as their agency’s retreat from strong enforcement against hunting practices which contradict the principles of fair chase and damage the very resource whose survival makes recreational hunting possible. more >>

Grizzly ScienceGrizzly Bear Biology in the Greater Yellowstone (October 1997)
Experts from various state and federal agencies chronicle the conflict between the practice of wildlife biology and the reality of bureaucratic politics within public resource agencies of the Greater Yellowstone Ecosystem. Their professional experiences exhibit common problems of bureaucratic dysfunction, including suppression of science, falsification of information, and harassment of those working to ensure the survival of the grizzly bear. more >>

Noah’s Ark is LeakingThe Department of Interior Abandons International Species Protection (May 1997)
The FWS has abandoned its legal obligation to protect international threatened and endangered species. There has been a decade-long de facto moratorium on the listing of foreign species. Commercial interests abuse the process by importing rare animals. more >>

Tarnished TrophiesThe Department of Interior’s Wild Sheep Loophole (October 1996)
According to its own specialists, the U.S. Fish & Wildlife Service is driving protected foreign game species to extinction through the illegal issuance of permits to import game trophies. Despite mandates to enforce both the Endangered Species Act and international conservation treaties, the Assistant Directorate for International Affairs (AIA) within the Fish & Wildlife Service is promoting importation of sports-hunted trophies of threatened and, in some cases, endangered species. more >>

Forest Service

Ruined RelicsCrumbling Cultural Resource Protection (October 2002)
Ruined Relics is an account by former cultural resources staff and volunteers of Los PadresNational Forest documenting the dramatic declineof one of the premiere historical preservationprograms in the nation. more >>

Stealing the TongassPlaying by Alaska Rules in the U.S. Forest Service (November 1996)
The institutional complicity of the U.S. Forest Service results in widespread commercial timber theft, massive scaling fraud and illegal exporting of unfinished public logs from the Tongass National Forest in Alaska. more >>

Unindicted Co-ConspiratorTimber Theft and the U.S. Forest Service (March 1996)
The Forest Service has unilaterally disarmed the war against major timber theft and fraud by removing its police from the forest protection beat. Salvage sales, supposedly designed to promote forest health, leave the national forests and the American taxpayers at the mercy of an industry honor system — an open invitation to steal. more >>

Business As UsualA Case Study of Environmental and Fiscal Malpractice on the Eldorado National Forest (February 1996)
The Forest Service has mismanaged the Eldorado National Forest in California and has attempted to cover-up wrongdoings. Agency managers have committed environmental violations costing tens of millions of tax dollars. more >>

Office of Surface Mining

Undermining the Public TrustAn Appraisal of the Office of Surface Mining by its Staff (August 1997)
This White Paper is written by Office of Surface Mining (OSM) employees. The Office of Surface Mining was created to protect the environment and local communities from the adverse effects of surface mining operations, but OSM employees have written this paper in order to communicate their concerns about OSM practices that allow environmental degradation, the disruption of the living environment of coalfield citizens, and massive environmental remediation and cleanup costs. more >>

Empty PromiseTwenty Years of Failure in Federal Strip Mining Regulation (August 1997)
OSM is being obstructed from enforcing environmental safeguards against the devastating effects of strip mining for coal. Agency mismanagement and improper actions have resulted in thousands of polluted streams and toxic health and safety hazards for communities. more >>

State Agencies

Last GaspCenter Hill Dam/Caney Fork River (August 2005)
The Middle Tennessee case study focuses on a stretch of the Caney Fork River downstream of Center Hill Dam. The dam has caused low dissolved oxygen (DO) in the tailwater (section of river below a dam), violating Tennessee’s water quality criteria and degrading significant trout habitat. The Caney Fork has been included in Tennessee’s 303(d) list of “water quality limited” waters for many years. more >>

Florida AsbestosThe Systematic Dismantling of the Asbestos Program in Florida (April 2005)
Although the Inspector General of Florida fears asbestos as an EPA-recognized human carcinogen, the state Department of Environmental Protection (FDEP) has not adequately committed itself to asbestos regulation. By reducing the enforcement arm of their Asbestos Program, FDEP has made the group ineffective as an oversight mechanism. more >>

To the Highest BidderBay County Florida for Sale (January 2005)
Private individuals and corporations are trying repeatedly to influence Bay Country officials, with the local residents and environment paying the price. more >>

Ten Ways to Clean Up Virginia’s EnvironmentRestoring Principles of Good Government at DEQ (January 2005)
In this pamphlet, employees of Virginia’s Department of Environmental Quality (DEQ) offer recommendations for how the agency can be improved to better protect the environment and serve residents. Suggestions include “get politics out of DEQ,” “commitment to enforcement” and “treat industry fairly.” more >>

Improving Florida’s DEPEmployees Speak Out (January 2005)
Similar to the Virginia pamphlet, this document lays out FDEP employees’ suggestions for how to improve the agency and, as a result, better protect the environment. The overwhelming opinion is the need to “go back to basics,” especially enforcement of its regulations. more >>

Stuck in the MudConstruction Sediment/Oliver Creek (October 2004)
Tennessee Clean Water Network (TCWN) and the Tennessee office of Public Employees for Environmental Responsibility (PEER) are conducting case studies in the three main regions of Tennessee – East, Middle, and West – to examine and expose examples of surface water pollution not being adequately addressed by regulatory programs under the Clean Water Act (CWA) and related state laws. more >>

Smokey Mountain SmelterSuperfund Site (October 2004)
The first case study, based in East Tennessee, involves the pollution of a tributary of the Tennessee River in South Knoxville. The source of this pollution is an abandoned hazardous waste facility, Smokey Mountain Smelters, which has been discharging pollutants into surface waters for many years without a permit or any form of treatment or containment. As the site history will describe, the State of Tennessee has been dealing with the facility for at least twenty years with little success. Smokey Mountain Smelters is representative of other waste sites in Tennessee that are causing or are likely to contribute to water pollution problems. more >>

FDEP Ignores AsbestosOther Violations at Construction and Debris Site Adjacent to Bay County’s Steelfield Landfill (May 2004)
FDEP received complaints involving the illegal dumping of materials, including oil and asbestos, at the facility, but has not formally enforced its own regulations. The problems of groundwater violations, as discussed in The Big Wheel Construction and Debris Landfill in Bay County – A Tale of FDEP Enforcement, continue and are compounded by the discovery of asbestos onsite. more >>

The Big Wheel Construction and Debris Landfill in Bay CountyA Tale of FDEP Enforcement (January 2004)
With the example of a construction and debris landfill in Bay County, Florida PEER determined that the policy of avoiding legal action has not made the Florida Department of Environmental Protection (FDEP) swifter and stricter. In this example, the company responsible for the landfill does not comply with FDEP standards for permits and water quality. Not pressing hard for compliance, FDEP lengthens the process and endangers nearby drinking water. more >>

Permit Irregularities, Federal Convictions, Political Connections, and FDEP Senior ManagementThe Troubling History of the Big Wheel C and D Disposal Facility (January 2004)
This PEER White Paper continues the study of FDEP’s lack of enforcement in the facility’s continued non-compliance with environmental standards. This portion of the study discusses the permit issued by FDEP and the background of the company that owns the facility. more >>

Science DerailedThe Hockomock Swamp Heads for Ecological Trainwreck (August 2002)
This PEER white paper is a case study in how politics derailed science in the routing of a rail line through one of the most environmentally sensitive areas in the Commonwealth of Massachusetts. more >>

No Walk in the ParkDismantling Tennessee’s State Park System (March 2002)
Reconfiguration of the system of state parks by Tennessee Department of Environment and Conservation Commissioner Milton Hamilton has reversed the parks’ mission. Closures, cutbacks, lay-offs and other changes have limited public access to, enjoyment of, and benefit from the parks, while privatization has made many parks concentrated solely on profit. more >>

Losing ParadiseThe Allagash Wilderness Waterway Under Attack (September 2000)
Each year, hundreds of canoeists and campers flock to northern Maine’s Allagash Wilderness Waterway. The Allagash Wilderness Waterway, however, is but a fragile strip of land. Despite its designation as wilderness, the outside world has begun to encroach on one of the Northeast’s last remaining natural treasures. This report, written by current and former state employees on the Waterway, gives an insider’s view of the past, present and future of this threatened resource. more >>

Fouling Our NestGross Negligence at the Missoula Wastewater Treatment Plant (September 2000)
Missoula’s Waste Water Treatment Plant is plagued by spills, bypasses and potential “backflows” which pollute the Clark Fork River, contaminate the groundwater aquifer and threaten the safety of the plant’s own drinking water supply. In addition, due to equipment breakdowns, the plant is emitting hazardous methane gas and has suffered mercury spills. This report details not only the chronic problems at the Missoula Waste Water Treatment Plant, but also the fact that the problems have been masked by upper management negligence and a system of cover-ups. more >>

Crude BehaviorMismanagement of the Onshore Oil Program by the Florida Geological Survey of the State DEP (August 1999)
Details a sorry record of systematic non-enforcement of key environmental and public safety regulations, contamination of Florida’s aquifers, hundreds of unplugged oil wells and open pits, and loss of royalty revenue owing to the state treasury. The Florida Geological Survey (FGS) has heretofore been a sleepy, obscure bureau which has historically viewed its job as serving the oil industry rather than the public. more >>

See No EvilThe Gutting of Michigan’s Wetlands Protections (September 1998)
Long touted for one of the best wetland regulatory programs in the country, in recent years Michigan’s Department of Environmental Quality has deliberately and systematically aided in the illegal destruction of the state’s diminishing wetlands, primarily by undermining essential enforcement functions. DEQ staff report that political influence has reduced the wetlands protection program to a shadow of its former self — a “paper tiger.” more >>

A Friend in High PlacesEnvironmental Protection for Sale in Connecticut (February 1998)
Connecticut’s Department of Environmental Protection obstructs the state’s environmental enforcement, principally by protecting politically-connected corporate polluters from appropriate legal action. A top-level DEP official routinely solicits political contributions from violators in exchange for favorable treatment. more >>

Dereliction of Duty A Profile of the Northwest District of the Florida Department of Environmental Protection (August 1997)
To please industry, the Florida Department of Environmental Protection fails to protect the environment and public health by violating safeguards and evading public oversight. A district office that has dismantled environmental permitting/enforcement programs is profiled. more >>

Paving Paradise An Insider Account of How Florida’s Wetland Protections Were “ERPanized” (July 1997)
Florida’s Department of Environmental Protection has not only failed to protect the state’s diminishing wetlands, but has deliberately aided in their illegal destruction. In the process, DEP’s wetland staff has been demoralized and rendered powerless by political manipulation of environmental regulation within the agency. more >>

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