What the BLM didn’t tell the public about a BLM National Wild Horse & Burro Advisory Board member

(photo: harrisondaily.com)

Fred T. Woehl, Jr. was re-appointed to the “public interest” position on the BLM’s National Wild Horse & Burro Advisory Board.  Mr. Woehl is the Chairman of this Advisory Board.

However, in two successive announcements regarding his appointments to this Advisory Board, the BLM did not inform the public that Mr. Woehl has been an employee of the U.S. Department of Agriculture (USDA) for approximately 37 years, with the Farmers Home Administration and Farm Service Agency.  The USDA’s Farm Service Agency gives loans to farming and ranching operations.

Although government employees can serve on Advisory Boards, the BLM continues to show a lack transparency when it does not inform the public of  important facts.

Mr. Woehl is a driving force in facilitating the wishes of livestock grazing interests (and the BLM) to kill all of the wild horses & burros.

The 2014 BLM announcement on the appointment of Fred T. Woehl, Jr. stated:

“Mr. Woehl has been involved in the horse community for more than 40 years as a trainer, natural horsemanship clinician, and educator. He is actively involved with the Equine Science Department at the University of Arkansas and taught Equine Science at North Arkansas College. He has served as a volunteer for the BLM’s Wild Horse and Burro Program for 10 years, conducting demonstrations of wild horse versatility and assisting with adoptions. Mr. Woehl worked as a senior agricultural adviser for the U.S. State Department from October 2008 to November 2009 in Iraq, where he was responsible for the development and implementation of agricultural programs and policy for the Ninewa Province.”

The 2017 BLM announcement on re-appointing Fred T. Woehl, Jr., stated:

“Mr. Woehl has been involved in the horse community for over 43 years as a trainer, natural horsemanship clinician and educator. He has been involved with the Equine Science Department at the University of Arkansas and taught Equine Science at North Arkansas College. He has served as a volunteer for the BLM’s Wild Horse and Burro Program for ten years, conducting demonstrations of wild horse versatility and assisting with adoptions. Additionally, Mr. Woehl worked as a senior agricultural adviser for the U.S. State Department from October 2008 to November 2009 in Iraq, where he was responsible for the development and implementation of agricultural programs and policy for the Ninewa Province. From November 2009 to March, 2011, he worked in the Kingdom of Jordan, for the Department of Interior’s International Technical Assistance Program, where he developed policies for horse use and trained the local Bedouin tribesmen in humane methods of training and in the use of horses at the Archeological Park of Petra. Mr. Woehl currently has four BLM mustangs that are used for demonstrations in Branson, Missouri, and good-will visits at nursing homes, schools and churches.”

There is no mention that Mr. Woehl is a career employee of the USDA.   However, the American public might want to be aware of this fact so that they can consider – is Mr. Woehl serving the “public interest” or the “government interest” on this Advisory Board?

Other sources:







Wild Horses and Barbed Wire Fences Do Not Mix – Checkerboard Roundup Day 8

Source:  wildhoofbeats.com

The black family

The black family

Wild Horses and Barbed Wire Fences Do Not Mix – Checkerboard Roundup Day 8

by Carol J. Walker, Dir. of Field Documentation for Wild Horse Freedom Federation

This morning we headed to the Bar X Road in Great Divide Basin for another day of watching helicopters chase wild horses into traps, then force them into trailers, then separating each horse from his or her family.

Far away from the trap

Far away from the trap

Driving horses into the trap in a cloud of dust

Driving horses into the trap in a cloud of dust

Yes, it is a very grim process. And the BLM has made it harder and harder for members of the public to observe this process. So placing members of the public who wish to observe this process as far away from the trap that the horses run into as possible is the logical solution for them. In this location, we were told to go on public land which was behind a barbed wire fence that separated us from the area the horses were being driven into. Even using the longest lens Canon makes, the horses looked like ants. The helicopter took the horses around a ridge so that we could not see them at all then just before the trap wings, drove the horses into the trap with a lot of dust. We had pretty much given up on being able to get usable images let alone be able to identify any horses. I was especially curious to see if any of the wild horses I had seen at the end of the day yesterday who were still free.

Coming down the hill toward us

Coming down the hill toward us

They look at us but were not concerned about us

They look at us but were not concerned about us

Turning away because of the helicopter

Turning away because of the helicopter

Suddenly a group a black horses with markings similar enough on their faces to mark them as family came trotting down the two track toward us, but behind the barbed wire fence. I asked the BLM staff with us to stand quiet so they would not frighten the horses away and we watched them get closer and closer. The horses were not particularly concerned about us, but really wanted to get away from the helicopter. Suddenly, a grulla stallion, mare and foal come running by, helicopter in persuit overhead. They finally run up the hill, while the black horses kept coming down the hill, getting closer to us. As the helicopter flies overhead they turn away from the fence.

Grulla mare with her foal

Grulla mare with her foal

They turn away

They turn away

But then two black horses come down the hill and the first one jumps the fence and the one behind tries to clear the fence as well but hits it hard and breaks the top barbed wire. It happens so suddenly that I am shocked, stop shooting as I normally do when there is a wreck – I am stunned and horrified.

Read the rest of this article HERE.

‘No Results Found’: Thousands of Climate Science Links Purged From USGS Online Database

Source:  Ecowatch.com

Yet another U.S. agency has deleted climate change information from its website. This time, the U.S. Geological Survey’s “Science Explorer” website—a tax-payer funded online database for the public to browse USGS science programs and activities—has been purged of thousands of formerly searchable climate science links.

The startling discovery was made by Peter Gleick, a climate scientist and member of the U.S. National Academy of Science.

“I didn’t realize how badly Trump has eviscerated access to federal #climate data, so I went and looked at the USGS site,” he tweeted Sunday.

In a series of tweets, Gleick noted the extent to which climate-related links have been expunged from the site a month after Donald Trump took over the White House:

  • In December, there were 5,932 climate science items linked there (9 were just pictures). Today there are 416 and 292 are just pictures.
  • In December 2016, 320 of those items were links to #climate data. Today, 0 links to data. 5,271 were web links. Now, 0 web links. “And the USGS “Effects of #Climate Change” webpage had 2,825 items in December. Today, that page has zero items.
  • And the USGS “Effects of #Climate Change” webpage had 2,825 items in December. Today, that page has zero items.

Gleick found the archived pages with the Wayback Machine, but pointed out on Twitter that “archived pages are no substitute for real public access.”

He also told ThinkProgress: “This is shocking in the extent of the changes, and distressing in the sense that publicly funded data and science should be easily accessible, not hidden, and the changes move us in the wrong direction. Every federal agency website has undergone changes like this.”

Read the rest of this article HERE.

BLM Web Disaster

SOURCE:  climatewest.org

“The Bureau of Land Management has already been under fire for using its website to promote fossil fuel industry interests, but this absolute elimination of online access and information is a scandal of epic proportions.”

Trump’s BLM Web Disaster


For those who don’t know, the U.S. Bureau of Land Management has been moving to a new website over the last several months. Far from a seamless transition, however, the move has been a complete disaster.

In the last several weeks, the agency seems to have completely disconnected its old website, effectively erasing any content that once existed on the web. While this wouldn’t be a bad thing if the Bureau had migrated all its content to the new website, unfortunately, this hasn’t happened. Making matters worse, the new website seems to be incomplete, lacks cohesion and any semblance of organization, is slow to load, and barely registers on web searches.

The result has been a complete web catastrophe: Information that was once publicly available is no longer accessible, public access to information and web pages seems to have been eliminated, and, more than ever, Americans are in the dark when it comes to the functions and actions of the U.S. Bureau of Land Management.

Let’s be clear, no matter what your interest or agenda is, this is a major affront to transparency. It also underscores how President Trump and his Secretary of the Interior, Ryan Zinke, are bent on shutting out the public out of the management of public lands and resources.

For years, the American public has relied on the Bureau of Land Management’s websites to access all sorts of information: recreation maps; instructions for filing applications for permits and claims; reports and analyses; news updates; staff contact information; and more. Now, it’s pretty much all gone.

Read the rest of this article HERE.

BLM’s website down Thursday night

Well, the ONLY source for any BLM information on the worldwide web that hasn’t been completely erased, the new minimalist BLM website, has been down.

The BLM should extend the deadlines on all planning documents since the public wasn’t able to access their website to get any information for hours tonight.  I doubt if the BLM website is “overloaded,” so in the future, if they know that work is to be done on the website and that it may be offline, they should let the public know ahead of time.  On the bright side, maybe they’re adding some of the tens of thousands of pages about the Wild Horse & Burro Program that they wiped off the internet.

Wild Horse Freedom Federation files two additional FOIA lawsuits against BLM

Wild-Horse-Freedom-FederationPO Box 390, Pinehurst Texas 77362

(800) 974-3684

For Immediate Release: July 5, 2017

Wild Horse and Burro Advocacy Group Funds Two More Lawsuits over Bureau of Land Management Freedom of Information Act (FOIA) Violations

Pinehurst, TX – Wild Horse Freedom Federation (WHFF) has announced that it has recently filed two additional FOIA lawsuits, so it is currently funding five Freedom of Information Act (FOIA) lawsuits, that allege the Bureau of Land Management (BLM) violated its duties under FOIA. Records sought are in connection with the BLM’s Wild Horse & Burro Program. Debbie Coffey, V.P. and Dir. of Wild Horse Affairs for Wild Horse Freedom Federation, and Wild Horse Freedom Federation are the Plaintiffs. The lawsuits are pending in the United States District Court for the District of Columbia in Washington, DC.

Attorneys Daniel J. Stotter of Corvallis, Oregon and C. Peter Sorenson of Eugene, Oregon filed the lawsuits.

R.T. Fitch, President and Co-Founder of WHFF states, “Wild Horse Freedom Federation serves in a “watchdog” capacity over the BLM’s Wild Horse & Burro Program. Unimpeded transparency of federal government agencies is the cornerstone of democracy.”

On January 21, 2009, former President Obama sent a memorandum to the heads of executive departments and agencies regarding an open and transparent government, stating that, “Transparency promotes accountability and provides information for citizens about what their Government is doing.”

President Obama continued, “The government should not keep information confidential merely because public officials might be embarrassed by the disclosure, because errors and failures might be revealed, or because of speculative or abstract fears. Nondisclosure should never be based on an effort to protect the personal interests of Government officials at the expense of those they are supposed to serve.”

Wild Horse Freedom Federation (WHFF) is a registered, Texas non-profit corporation with 501c3 status in all 50 states. WHFF puts people between America’s wild equids and extinction through targeted litigation against governmental agencies whose documented agendas include the eradication of wild horse and burros from public, federal and state lands. WHFF is funded exclusively through the generosity of the American public.


Media Contact:

R.T. Fitch
President/Co-Founder of Wild Horse Freedom Federation
rtfitch@wildhorsefreedomfederation.org ~ rt@rtfitch.com
(713) 632-4573

To Download Release Click (HERE)

From Animal Welfare Institute: USDA Still Stonewalling on Access to Enforcement Records

” When BuzzFeed, which consulted with AWI for an April 28 story on the issue, filed a Freedom of Information Act request for records pertaining to the site scrub, the USDA provided 1,771 pages of records with every single page completely blacked out—all information redacted.” – Animal Welfare Institute

SOURCE:  Animal Welfare Institute at awionline.org

After the public outcry regarding the US Department of Agriculture’s scrubbing of inspection records and other important enforcement documents from its website, the department began to restore selected records online. These included annual reports for research facilities and inspection reports for some registrants and licensees.

The bulk of the data remains missing, however. The USDA has not posted a single enforcement record (e.g., warning letter, stipulated penalty, or complaint) since August 2016. Also remaining offline are about two-thirds of the inspection reports that the USDA says “may contain personal information implicating the privacy interests of individuals and closely-held businesses.” These pertain to thousands of regulated entities (breeders, dealers, exhibitors, and others licensed or registered under the Animal Welfare Act).

Read the rest of this article HERE.

BLM claims selling wild horses to kill buyer Tom Davis was selling them to a “good home”

by Debbie Coffey, V.P. & Dir. of Wild Horse Affairs, Wild Horse Freedom Federation All Rights Reserved. Copyright 2017

On the Bureau of Land Management’s new website, on the Program Data page for the Wild Horse & Burro Program (under the Wild Horse and Burro Sales to Private Care tab), the BLM claims “It has been and remains the policy of the BLM, despite the unrestricted sales authority of the Burns Amendment, NOT to sell or send any wild horses or burros to slaughterhouses or to “kill buyers.”

The BLM claims “Wild Horses and Burros Sold to Good Homes” but then includes a total of 402 wild horses and burros sold in Fiscal Year 2012. (In this 402 total, 320 were horses and 82 were burros.)

BLM sale logs obtained by us in Freedom of Information Act requests indicate that in Fiscal Year 2012, the BLM sold 239 wild horses (almost 80% of the 320 horses that were sold) to kill buyer Tom Davis of La Jara, CO.  Many, if not all, of these wild horses went to slaughter in Mexico.

Does this look like a “good home” to you?

BLM states it has a policy not to sell wild horses and burros to kill buyers, but:

  1. On 1/11/12, Lester T. Duke (BLM Burns, Oregon) sent an email to BLM’s Bea Wade, regarding 50 sale authority horses, noting that a “large portion”of the mares were “possibly pregnant.” Lester asked if they should ship to long term holding or hold them at the corrals for sale. Bea responded that she forwarded the email to Sally Spencer. After a couple of more emails regarding this, Sally finally sent email on 2/23/12 that Tom Davis would purchase the horses, starting with the load of mares from Burns, Oregon. (About a week later, BLM sold Tom Davis 32 horses from the Burns, Oregon corrals.   19 of these horses were mares)
  2. On 4/19/12, Deanna Masterson, Public Affairs specialist for the BLM Colorado state office, sent an “Early Alert” email to “WO BLM/DOI Officials” (Jeff Krause, Leigh Espy, Helen Hankins, Steven Hall, Tom Gorey and Sally Spencer) that “The Colorado Department of Agriculture notified the BLM Colorado State Office of a Colorado Open Records request from David Phillips, a freelance journalist, for brand inspection and transfer paperwork for horses the BLM sold to Tom Davis of La Jara, Colorado. Phillips indicated he suspected Davis of selling these horses for slaughter to Mexico.”
  3. On 4/24/12, the BLM, alerted that Tom Davis was suspected of selling horses for slaughter, still sells 106 wild horses to Tom Davis.
  4. On 5/17/12, Sally Spencer sent out an email, marked “High” importance, to 21 people (Joe Stratton, Roger Oyler, Amy Dumas, Fran Ackley, Karen Malloy, Christopher Robbins, Jared Bybee, Robert Mitchell, Alan Shepherd, Rob Sharp, Robert Hopper, Gus Warr, June Wendlandt, Joan Guilfoyle, Mary D’Aversa, Dean Bolstadt, Jeff Krause, Tom Gorey, Debbie Collins, Lili Thomas, Bea Wade) and BLM_WO_260 WHB Communications, telling them a reporter was calling about Tom Davis. Spencer asked Joe Stratton to send out a message to all facility managers and the state leads to send a message out to all WHB Specialists that if they were asked “specifics” about a purchaser, they shouldn’t respond for privacy issues…”

If BLM personnel were so convinced that they sold the wild horses and burros to a “good home,” why all of the urgency and secrecy?

If the BLM truly believes these horses were sold to a “good home,” why isn’t Tom Davis’ photo featured on the BLM’s Wild Horse & Burro Program page on the BLM’s new website, instead of the photo of the young blonde girl? After all, the BLM sold Tom Davis 1,794 wild horses and burros from 2008-2012.

If the BLM thinks they’re fooling us, they’re only fooling themselves.

All documents referenced above can be seen HERE.

The Bureau of Land Management is scrubbing their trail on the internet

After NBC News wrote about the Bureau of Land Management featuring a photo of a coal bed at the top of their website, the BLM changed it… to now feature this photo of an oil & gas pipeline.

by Debbie Coffey, V.P. & Dir. of Wild Horse Affairs, Wild Horse Freedom Federation                                                                    All Rights Reserved.          Copyright 2017

The Bureau of Land Management is scrubbing most of its links off of the internet, and in doing so, erasing much of its history from public view.

Many of the blm.gov links that are still remaining on the internet at this point say “page not found,” or the links are no longer cached.

The BLM also suddenly removed state and district websites.  Instead, you will now find “landing pages” that direct you to only one main Bureau of Land Management website.  (You can look at the new BLM website HERE.)

I called a BLM Public Affairs Specialist to ask some questions about the defunct websites and links.  This person said in the past there were about 90,000 pages (and then a bit later stated that it could possibly be only about 60,000 pages) of BLM content on the internet, but that all of these pages couldn’t be maintained or updated, and weren’t centralized.  This person said the BLM’s prior content management system was outdated.

Most importantly, this person also said there were now standards to reduce the amount (of pages/content).

Who made the decision to even have a standard to reduce content available to the public on the internet?  During this website transition, who is making the decisions, and on what basis, of what data to migrate, or not to migrate, to the new BLM website?  These decisions cherry pick what information will be available to the public in the future.

Make no mistake, this “reducing the amount” of content on the internet is erasing many of this agency’s past actions, activities, and government documentation.  Many of these links had historical value.  For example, the BLM activities of BLM employees Sally Spencer and Lili Thomas over the years are now gone.  These types of links on the internet didn’t need to be “maintained” or “updated.”  They were historical in nature.

In the past, in doing a google search for Sally Spencer (a longtime BLM employee, and the Marketing Specialist famous for selling so many wild horses and burros to kill buyer Tom Davis), she was included on many, many BLM government links.  I went to the BLM’s new website and searched “Sally Spencer,” and only 3 items appeared.  When I searched “Lili Thomas” (another longtime BLM Wild Horse & Burro Program employee who oversaw the BLM’s Long Term Holding facilities for wild horses for many years), only 4 items appeared.  And when I searched “John Neill” (a longtime Palomino Valley Center manager), all that came up was “No results found.”

These individuals are BLM personnel who have been central in management issues in the BLM’s Wild Horse & Burro Program, as evidenced by FOIA documentation garnered by the late Dr. Patricia Haight of The Conquistador Program.

Even when I searched the new BLM website for “Dean Bolstad” (the Division Chief of the Wild Horse & Burro Program) only 2 items appeared.

(Although, luckily, thanks to In Defense of Animals, you can still go online and see this youtube video of Lili Thomas saying “working with wild horses is not a pretty sight” at a public meeting.)

What I can’t understand is, if the new content management system is bigger and better, why couldn’t the new content management system have contained all of the old data along with new data?  If this agency were truly transparent, they would add data, not reduce data, available to the public on the internet.

At first the Bureau of Land Management only removed the Directories for District offices and Field Offices, making it difficult, for example, to find out who was the Wild Horse & Burro Specialist, Hydrologist, Range Management Specialist or other personnel in any particular district or field office or to find an email address or telephone number for them.  BLM personnel frequently transfer to other offices and states, so it was already hard enough to try to keep up with who was where.  But now the public really doesn’t have a clue who is doing what or where.

You used to be able to go to the home pages of BLM state and district websites, and get a quick overview of not only roundup plans for wild horses & burros, but mining expansion plans, oil & gas lease sale plans, and other uses of our public lands in that area, all in one place.

Now, the BLM has divided these by topics or by “regions,” on their new website.   Under the “region” of Nevada (we call them states here in the U.S.A.), there isn’t a box for wild horses & burros (only oil and gas leasing, greater sage grouse, Great Basin Landscape Conservation Cooperative, Information Access Center, Nevada Resource Advisory Councils & Federal Register Notices).

By scattering information all over this one “centralized” website, the BLM has made it much harder for the public to put together the pieces of information for a clear picture about the multiple uses of our public lands in any one area.

The Program Data page for the Wild Horse & Burro Program is HERE.  When I clicked on the box for Historical Program Data and Public Lands Statistics, I noticed something was missing that used to be available to the public.  It was the column on Adoptions by Locations & Date.  Information from the years 2009-2015 were previously available.

The biggest reason this data was important is because it let the public know the dates of adoption events (including internet adoptions), the locations of the events, the number of the wild horses and burros offered for adoption (until Fiscal Year 2014) and the number of wild horses and burros that were actually adopted at each event.

The BLM likely stopped reporting the number of horses & burros offered at adoption events in Fiscal Year 2014 because it didn’t want the public to know how many horses & burros were racking up “strikes” by not being adopted.  When a wild horse or burro isn’t adopted after 3 events and gets 3 “strikes” it can be sold without restriction (to slaughter), no matter how young it is.  Even this seemingly small reduction of data indicated a lack of transparency by this agency.

Another reason this data is important to the public is because it let the public see what areas of the country adopt the most (and the least) wild horses & burros.

While the new BLM website contains a lot of information, it seems we have lost much more information that was once available on the internet, but was not migrated to the new BLM website.  For example, the BLM News Release on its promised investigation into the deaths of wild horses at the Scott City feedlot is on the internet, but as of today, is not one of the 63 News Releases available to the public on the BLM’s new website.

We will never know how much, or what, the BLM has removed from the internet.  The BLM’s scrubbing of their trail on the internet has not only erased part of the history of this government agency, it is censorship, and it is the equivalent of a modern day book burning.



Filmmaker James Kleinert had to fight to obtain requested Freedom of Information Act (FOIA) records from the Bureau of Land Management, and filed a lawsuit against them.  Kleinert’s Wild Horses & Renegades facebook page included this edited message from his attorney, Daniel J. Stotter, “Just received a nice win from the DC federal court in our FOIA case James Kleinert v BLM.   An excellent FOIA ruling, setting favorable law on our adequacy of search objection issues, and strongly admonishing the BLM for its improper FOIA withholdings and their failure to meet the legal requirements of FOIA exemptions (b)(5), (b)(6) and (b)(7)(c).   Here’s a link to the court’s decision:
KLEINERT v. BUREAU OF LAND MANAGEMENT, No. 1:2014cv01506 – Document 29 (D.D.C. 2015)

SOURCE:  justia.com

Excerpts from Opinion by the Court on James Kleinert v Bureau of Land Management:
Kleinert is a documentary filmmaker whose work has focused on American wild horses.  This vocation has brought Kleinert into repeated contact with BLM, which manages public lands where wild horses live and administers the Wild Free-Roaming Horses and Burros Act of 1971.  Kleinert and the agency have not had an entirely cordial relationship: Kleinert has sharply criticized BLM’s treatment of wild horses.  In recent years Kleinert has come to believe that “BLM has been targeting [his] filming of wild horses on the public lands . . . by seeking to restrict [his] access to film at locations that would depict these issues.”

This targeting, he suggests, “is related to the agency’s opposition to, and disagreement with, the content of [his] films, and [his] advocacy as to these issues,” and is aimed at limiting his “ability to facilitate public oversight of the agency’s actions.”

When nearly a full year passed without the delivery of any records, Kleinert filed this suit to compel BLM to respond to his request.

It seems, though, that BLM had sent Kleinert a compilation of responsive records in January 2014, but for reasons unknown— they never showed up in Kleinert’s mail.

Kleinert cross moved for summary judgment, arguing that many of the redactions were unjustified, and also that BLM had not conducted an adequate search of its records.
Kleinert’s motion prompted BLM to take another look—which revealed that the agency had indeed failed to provide a number of responsive records.
But Kleinert contends that BLM has still not demonstrated the adequacy of its search or the propriety of many redactions, including some in the newly released materials.
The Court noted (in part):
The Court was in doubt about whether the agency conducted a reasonable search.
For the most part, BLM failed to convince the Court that their redactions were justified.
With respect to the Exemption 5 (deliberative process) redactions that Kleinert challenged, BLM failed to show that its invocation of the deliberative process privilege was justified.
BLM’s submissions did not convince the Court that some redacted materials “reflect the personal opinions of the writer rather than the policy of the agency.”
BLM’s reliance on Exemption 7(C) for the most part faltered at the first step because BLM did not convince the Court that the bulk of the redacted records were “compiled for law enforcement purposes.”
(Regarding Exemption 7), “the individuals whose names and titles have been redacted here fit none of those categories.  They are BLM employees who signed non-confidential official documents that happened to be reviewed and summarized years later by investigators examining tangentially related events.  The risk of harassment, embarrassment, or reputational damage here — if not absent entirely—seems about as close to nil as it could get.”
Given that the privacy interests here are truly de minimis, the balancing favors disclosure.  Kleinert has articulated a significant public interest behind his FOIA request: determining whether BLM is unfairly restricting his ability to film on public lands because of his views.  This inquiry of course has special significance for Kleinert, but the public generally has an interest in learning if an agency is retaliating against its media critics.
“Exemption 6 does not categorically exempt individuals’ identities.”  The absence of such a per se rule is fatal to BLM’s invocation of Exemption 6, for the agency has failed to explain with meaningful specificity why releasing the challenged information would significantly threaten anyone’s privacy.  …And the Court will certainly not accept the suggestion that the remote possibility of harassment means that every disclosure of a name implicates a significant privacy interest.