protect colorado
see CRED etc astro
https://moneytrails.org/noble-energy/
see local regs
https://www.desmog.com/2022/09/14/house-committee-pr-climate-disinformation/
On September 14, a congressional committee probed the history that PR firms have played in creating and spreading climate disinformation in order to block climate policy and promote fossil fuel interests.
The hearing, held by the U.S. House Natural Resources Committee, Subcommittee Oversight & Investigations, invited several firms, including Singer Associates, Story Partners, and Pac/West Communications. None of them showed up.
Instead, the hearing heard from several witnesses, including experts in the PR industry. One of them was Christine Arena, a former VP at Edelman who now researches and exposes greenwashing and industry obfuscation. Arena laid out three overarching campaign strategies that PR firms use on behalf of their fossil fuel clients, citing a study from Brown University researchers Robert Brulle and Carter Werthman. Those strategies are corporate image promotion, third-party mobilization (astroturf groups), and delegitimization of the opposition.
“The U.S. oil and gas sector has always pushed for policies that allow for new fossil fuel expansion, and against policies that would reduce demand,” Arena said in a prepared testimony. “But what has changed recently is the intensity of the industry’s pursuits, and the vast resources it deploys through public relations and lobbying efforts meant to crush potential regulatory obstacles in its path.”
The oil industry and its hired PR hands continue to deploy these strategies. A recent example Arena cited was the oil industry’s effort to opportunistically seize on Russia’s war in Ukraine to promote long-standing policy wishes, while misleading the public by blaming climate policy for causing higher energy prices.
These tactics are especially aggressive at the state and local level, where “brute financial force” is used to kill off climate initiatives, Arena added.
That power imbalance was on vivid display in Colorado in 2018 when grassroots activists succeeded in getting a ballot initiative put to voters that would have imposed greater setback distances on fracking operations, limiting how close to homes and schools new oil and gas wells could be drilled. A year earlier, two deadly oil and gas infrastructure explosions had rocked Firestone, Colorado.
The industry poured money into that election, outspending community and environmental groups by a factor of more than thirty to one. Noble Energy,a large fracking company (now owned by Chevron), hired DC-based PR firm Story Partners, to help defeat the measure. Story Partners created two astroturf campaigns, based on the firm’s research that showed that support for setback distances declined when voters heard about the “devastating consequences” that it would have on the state’s economy. The campaign ran ads to promote “clean” natural gas, warn of damage to Colorado’s economy, and positioned Noble Energy as a responsible partner. Story Partners still displays its campaign to defeat the ballot initiative on its website as a successful “case study” of how it protected its client’s assets.
The House committee also heard from Anne Lee Foster, who held an unpaid position in 2018 for Colorado Rising, a grassroots group supporting the ballot measure to establish drilling setback distances. She spoke about the multiple instances in which people would harass her and her colleagues as they tried to gather signatures.
Around that time, Colorado Public Radio reported that an internal Anadarko Petroleum document, leaked to Colorado Rising, asked employees to report the locations of signature gatherers via a phone texting system. Once the location was identified, counter-protesters appeared at a moment’s notice, shouting and harassing the signature gatherers and passersby who considered signing on to the ballot initiative effort.
According to a report produced by the House committee, oil companies including Anadarko Petroleum, Noble Energy, and Chevron, had set up two front groups, “Protecting Colorado’s Environment, Economy and Energy Independence” (Protect Colorado), and “Coloradans for Responsible Energy Development” (CRED). Those two groups then funneled most of their proceeds to an Oregon-based PR firm called PAC/West. The two front groups offered a “buffer” between the oil drillers and the PR campaign, the committee report said.
Although it was later deleted from its website, PAC/West described how it was paid by Anadarko Petroleum and Noble Energy to “lead a statewide education campaign” to defeat the ballot measure. Ultimately, the ballot measure was narrowly defeated at the polls in 2018.
“I personally suffered from what I feel is stalking or harassment in a number of other circumstances throughout this campaign,” Anne Lee Foster told the committee on Wednesday in her prepared testimony.
That was one small example of a web of influence between a handful of PR firms and the oil and gas industry. “Let me be clear: There is nothing standard or ethical about these practices. They are deceptive communications practices that mislead our citizenry and undermine our democracy,” Arena said.
The work that PR firms do goes far beyond simply promoting the image of their clients, according to Melissa Aronczyk, an associate professor at Rutgers University’s School of Communications & Information, another witness at the congressional hearing.
“Public relations firms often present themselves and their work in terms of facilitating or amplifying ideas or information. In fact, public relations is not only communicating ideas and information but coming up with those ideas and creating that information,” Aronczyk said in her testimony. PR firms provide long-term strategic planning, set up front groups, manufacture the illusion of support, and monitor and target opponents. She said the work goes back many decades.
PR firms also operate a broad network of influence out of public view, sharing information among multiple clients and trade groups, which allows companies to “minimize the reputational and financial risk of speaking out against climate action,” Aronczyk said.
“Because this coordinated infrastructure of anti-environmental action is operating behind the scenes, members of the public and lawmakers have no way of knowing if the campaigns operating on behalf of fossil fuels are real or manufactured,” she added.
But the growing pressure on the PR industry is having an effect. Clean Creatives, a climate campaign targeting the advertising industry, says that nearly 400 PR firms have signed a pledge to not work with coal, oil, and gas companies.
“We’re seeing the beginning of a transformation of the PR and Advertising industry when it comes to climate,” Duncan Meisel, executive director of the Clean Creatives campaign, said in a statement. “Oil and gas companies used to be seen as prestige clients, now agencies are embarrassed to admit that they work for them. But this dirty work is still going on in the shadows, making the spotlight of this House hearing and investigation all the more important. The future of creativity is clean and it’s time for agencies to step into the light.”
One PR firm was not at Wednesday’s hearing: FTI Consulting. The House committee is investigating FTI, which has refused to turn over documents requested by the congressional investigators.
“We initiated the subpoena process for FTI Consulting, which has one of the worst reputations in the business. The negotiations are ongoing. The trajectory is sadly not good,” Rep. Katie Porter said in her closing comments on Wednesday. “What are they trying to hide? Is it their creation of fake grassroots groups for their clients to hide behind? Was it the creation of fake social media profiles to track plans of activist groups? Or is there something worse? The harder FTI Consulting fights, the more it appears that they have a lot to lose by having their tactics exposed through oversight.”
She added: “We are just getting started.”
==
9 22
2. Third-Party Mobilization
The general public is less likely to be convinced by a narrative that appears only to serve a special
interest, especially one with significant reputational liabilities, such as the oil and gas industry. PR
firms consequently work to make the industry’s positions seem widely supported by a range of
ostensibly unrelated groups, manufacturing the appearance of representing the broader public
interest.32 This tactic can take the form of third-party spokespersons, “generating favorable media
coverage, attributing advertisements to [a] third-party group instead of to the organization, creating
supportive social media, and mobilizing “astroturf” groupsof public supporters.”33 Oil and gas
companies have also created and funded nonprofit entities, which they used to organize opposition
to climate policies.
34 Through these front groups, the industry has funneled tens of millions of
dollars to public relations firms to manage media campaigns.35
A prominent example of such an approach is the successful defeat of a 2016 effort to put on the
Colorado ballot two initiatives that would have altered Colorado’s constitution to (1) give local
municipalities the ability to ban fracking, and (2) prevent oil and gas development within a 2,500-
foot buffer zone from occupied buildings and parks, waterways, playgrounds, and other “areas of
special concern.”36 Seeing an existential threat to its “license to operate,” Noble Energy, a major
natural gas company operating in Colorado (later bought by Chevron), hired PR firm Story
Partners to help it prevent these safeguards from becoming law.
The Committee has obtained documents that reveal, in the PR firm’s own words, howStory
Partners successfully designed and executed its multipronged plan to defeat the initiatives at the
signature-gathering stage (Appendix 5). Story Partnersachieved this through tactics including
astroturfing and careful analysis of which kind of message was most likely to persuade people that
the ballot measure would economically harm not only Noble Energy and “the industry at large,”
but the general public as well.37 This campaign and its techniques are discussed in greater detail in
the final section of this memorandum.
Third-party mobilization can also directly reach policymakers and their staff. Following the
Russian invasion of Ukraine, House Natural Resources Committee staff received a series of seven
...p 11
Staff from “HBW Resources” sent the emails and identified themselves as representatives of CEA,
describing it as “a nationwide grassroots organization that supports energy policies ensuring
abundant, affordable, reliable, and sustainable domestic energy supplies.”CEA claims to have
more than 550,000 individual members and to represent “a broad list of organizations that include
farmers, academia, conservation groups, truck drivers, laborers, trades-people, energy producers,
manufacturers, business owners to so much more.”51
Watchdog organization Energy and Policy Institute calls CEA an industry front group, and its
positions align closely with fossil fuel interests. CEA has been accused of engaging in astroturfing
on behalf of the major extractive energy industries.52 The organization received a score of “E-”
from LobbyMap (on an “A+” to “F” scale) on their climate policy’s alignment with the goals of
the Paris Agreement, reflecting CEA’s work to obstruct climate policy and energy transition at the
state and national level.53
HBW Resources, a self-described “government affairs, advocacy, public relations, and
communications firm,”54 appears to run CEA. The organization is run out of HBW’s Houston-based office.
55 IRS forms indicate that CEA has no paid staff and its chief officers include HBW
employees, such as CEA President and Director—David Holt—and Vice President—Michael
Whatley.
56 Since 2010, HBW Resources has been CEA’s highest paid contract by far. Over this
time, 53% of all of CEA’s expenses were paid to HBW, totaling nearly $17 million.57
Large sums
were also paid to two PR firms currently under investigation by this Committee, FTI Consulting
and Story Partners.58
p 12
The source of CEA’s funding is unclear. Since 2010, CEA has reported revenues of over $34.7 million made up almost entirely of contributions and grants.59 As a registered 501(c)(4) organization, CEA is not required to disclose its donors. 60 However, CEA’s members include major oil corporations such as Chevron, ExxonMobil, and Shell USA.61
3. Delegitimization of OppositionDelegitimizing competing narratives is the final major strategy PR firms use to shore up the fossil fuel industry’s messages.62 PR firms use a range of tactics to undermine other narratives and their messengers, from disputing the facts to attacking individuals and organizations’ “reliability and reputations.”63 The following case study illustrates the extreme and unethical methods some PR firms use. Industry Defeat of Colorado Anti-Fracking Ballot Measures
...
P 14
...reaffirmedNoble Energy as a strong partner in the community.”74 Meanwhile, print and digital
advertisements “creatively told the story of the unintended consequences of the proposed ballot
measures,” and “informed voters of the products and services dependent on oil and natural gas,
both from a funding point of view and from a resources perspective.”75 These narratives position
Noble as a socially responsible member of the community, while eliding the full environmental
and public health burden the fossil fuel industry creates in Colorado.
These advertisements against proposed fracking restrictions ran “under the brand of the South
Metro Denver Chamber of Commerce (SMDC),” and “concurrently under the banner of the
Consumer Energy Alliance (CEA),” creating the illusion of third-party mobilization.
76 Notably,
“guerilla marketing teams attended dozens of Colorado events and engaged hundreds of thousands
of citizens.”77Story Partners’ budget for this campaign is not public information, but CEA’s tax
filings show that the organization paid the PR firm $535,442 in 2016 for “communications,”
presumably for this effort.
78
Story Partners called the campaign a “huge success,” and “an enormous, measurable achievement
for Noble Energy.”79 The PR firm noted that a survey, “after just two months of campaign activity,
indicated that support for the specific ballot measures dropped to its lowest point in our research,
and opposition to the measures had increased. For the first time, support for the measures was
under 51 percent, and it was clear the campaign messages were working and recalled.”80The PR
campaign had successfully stopped climate legislation.
Two years later, there was an effort to revive the buffer zone ballot measure. Proposition 112(aka
initiative 97) was a 2018 Colorado ballot initiative designed to mandate that new oil and gas
development, including fracking, be sited a minimum distance of 2,500 feet from occupied
buildings such as homes, schools, hospitals, and other areas designated as vulnerable. The measure
was brought by grassroots environmental groupColorado Rising.81
Industry pushback was coordinated, sophisticated, and heavily funded. Oil and gas firms funneled
millions of dollars into coordinated PR campaigns to defeat Proposition 112.82 Oil and gas industry
[CRED protect colo]
P18
attempted to end their contract while demanding additional payments.96,97 When Colorado Rising
contracted with another signature-gathering firm, the firm broke the contract several days later. In
a recorded conversation shared with the Committee, a subcontractor admitted to taking a bribe of
“a lot” of money to stop working with Colorado Rising. He also stated the people who paid him
off had asked him to give them the signatures he had gathered for Proposition 112, but he did not
confirm or deny that the request came fromProtect Colorado, the Pac/West front group. (Appendix
7(a))
98
Volunteers for Colorado Rising also experienced harassment in their volunteer and personal
capacities. Members of the opposition attempted to infiltrate their campaign trainings, showed up
repeatedly at their press conferences and outside their campaign office to monitor them, and
monitored the campaign’s delivery of signatures to the Secretary of State’s office. In her personal
life, the witness was followed around town by unidentified men – who also showed up to record
Colorado Rising press conferences – and received unsolicited texts from one of the people who
attempted to infiltrate their campaign (Appendix 7(b)).
99 Another lead volunteer received
harassing mail at her home address (Appendix 7(c)).[gun in waistband?]
100
CONCLUSION
For decades, the oil and gas industry denied or downplayed climate change and its role in causing
it. Now that fossil fuel companies and trade groups can no longer get away with outright denial,
they pay millions to PR firms to wage sophisticated and varied campaigns that go far beyond mere
marketing. These efforts include falsely depicting industry as joining the fight against climate
change, engineering astroturf “citizen” groups to advocate for industry interests and defeat
legislative proposals, and using unscrupulous tactics to sabotage genuine policy solutions and
attack community advocates. These modern techniques are arguably far more insidious than the
denialism of the past, thanks to the pivotal involvement of PR firms.[long appendix rich st'd CEA, threat ltr]
https://www.ucsusa.org/sites/default/files/2021-10/Colorado-Targeted-by-Fossil-Fuel-Industry-Disinformation-Playbook.pdf
40 pp
Colorado Targeted by
Fossil Fuel Industry’s
Disinformation
Playbook
Climate Deception Harms Communities’ Health
and Safety
www.ucsusa.org/resources/colorado-fossil-fuel-industry-disinformation
https://doi.org/10.47923/2021.14291
CONTENTS
Chapter 1 Deceiving the Public: The Disinformation Playbook 4
The Disinformation Playbook and Colorado Oil and Gas Operations 5
Chapter 2 Disinformation Tactic: The Fix 7
Lobbying to Weaken Public Health and Safety Protections and Enhance Fossil Fuel Profits 8
Overwhelming Public Voices to Thwart Ballot Initiatives 9
Table 1. An Example of How Industry Spending Overwhelms Health and Safety 10
Pitting Local Leaders Against the Health and Safety of Their Constituents 11
Influencing Public Policy Positions from Inside and Out 11
Using Proxy Groups to Confuse the Public and Undermine Support for Climate
Accountability Lawsuits 12
Chapter 3 Disinformation Tactic: The Diversion 13
Elevating Industry Interests Above Community Voices 13
Fabricating the Appearance of Local Support 14
Figure 1. Colorado’s Climate Disinformation Complex 15
Greenwashing Your Screens 16
Chapter 4 Disinformation Tactic: The Screen 18
Building Credibility by Hiding Behind Trusted State Institutions 18
Burnishing Industry’s Reputation through Association with Respected Nonprofits 19
Chapter 5 Disinformation Tactic: The Fake 21
Chapter 6 A Litany of Harms: Health and Safety 23
Cancer-Causing and Other Dangerous Chemicals in the Air and Water 24
Poor Air Quality 24
New Research Identifies Even More Dangerous Ozone Problems 25
Figure 2. Fossil Fuel Industry Emissions are Higher in High Racial-Minority Census
Tracts 26
Dangerous Inactive Wells 26
Climate Change Impacts 27
Chapter 7 A Litany of Harms: Economic 28
Bogus Complaints about High Taxes 28
Inflated Jobs Claims 28
Union of Concerned Scientists | 3
Figure 3. Oil and Gas Extraction’s Boom-and-Bust Contribution to the Colorado
Economy 29
Other Harms, Some Difficult To Monetize 29
Chapter 8 Recommendations 31
Acknowledgments 32
...For more than a decade, Colorado oil and gas exploration and development have intensified, often putting dangerous and polluting industrial activities in close proximity to homes, schools, playgrounds, and other public spaces. This report exposes how the fossil fuel industry positions itself as the backbone of the state economy, often framing any community opposition to this industry’s dangerous operations as a fight against local interest in the form of tax revenue, school funding, and jobs. The industry largely glosses over evidence it causes health, economic, or environmental damage, and its clout enables oil and gas extraction and expansion to continue with little regard for those facing the adverse health and economic impacts. In Colorado, the oil and gas industry is comprised of powerful transnational corporations, including ExxonMobil and Chevron, along with companies such as Noble Energy (now owned by Chevron), Anadarko (now owned by Occidental Petroleum), and Suncor (a large Canadian tar-sands operation with close ties to ExxonMobil and Royal Dutch Shell).
The industry’s interests are represented by heavyweight national lobbying outfits like the American Petroleum Institute (API), as well as local trade associations, like the Colorado Oil and Gas Association (COGA). A proliferation of industry-created and backed front groups includes several with ties to the private multinational conglomerate Koch Industries.They often all work together to run the same Disinformation Playbook. Of course, the fossil fuel industry uses similar tactics and wields considerable political clout in other oil- and gas-producing states and at the federal level. Consider its success in stalling any meaningful climate action for more than two decades and its ability to despoil public and Native lands and waters with drilling and pipelines. Or consider the API’s nationwide TV and digital ad campaign, launched ahead of the 2020 elections and targeting not only Colorado, New Mexico, Pennsylvania, and other key oil- and gas-producing states but also Wisconsin, Michigan, and other political swing states (API 2020a; API 2020b)....
Lobbying to Weaken Public Health and Safety Protections and Enhance Fossil Fuel Profits
In the early years of fracking in Colorado, API and its local division, the Colorado Petroleum Council (CPC), pushed the state legislature to enact the little-known ad valorem tax credit, which allows oil and gas companies to deduct local property taxes from the severance tax that fossil fuel companies must pay to the state. As local property taxes have increased, particularly for oil and gas operations, the state’s pool of severance taxes, based on production and profits, has shrunk—even though severance-tax revenues are needed to remediate abandoned and orphaned wells. Such wells are often underground pathways through which toxic fluids and gases migrate upward into air, water, and homes. These wells are also a significant source of leaked methane, a heat-trapping pollutant that has 80 times the warming power of carbon dioxide during the first 20 years after it reaches the atmosphere (Bushkin-Bedient et al. 2020).
Thanks to the ad valorem tax credit, some oil and gas operations have paid nothing to the state in recent years, leaving old wells unremediated and dangerous to residents (Eason 2020; Legislative Council Staff, n.d.; Silbaugh 2020). In April 2017, a house in Firestone, Colorado blew up, killing two residents and seriously injuring a third. The explosion was traced to gas leaking from an old well that had not been disconnected from the wellhead or properly capped (Markus 2018; Osher 2017; Svaldi and Finley 2017).In direct response to the explosion, the legislature took up a science-based bill to require regulators to map oil and gas pipelines throughout the state; a filibuster in the Republican-controlled state Senate killed the proposal. Lobbying disclosure reports and campaign-finance records showed that Anadarko and Noble Energy, both of which opposed the bill, spent significantly in support of Senate Republican candidates in the 2016 election as well as to directly lobby against the bill (Osher 2017; Sirota 2017).
Also in April 2017, the legislature considered a bill mandating that new oil and gas facilities be set back a certain distance from school property. Such a policy is intended to reduce children’s exposure to toxic releases by keeping them a safer distance from potential explosions. By a one-vote margin along party lines, a Senate committee killed the bill to establish a buffer zone separating oil and gas wells and associated facilities from occupied buildings and property lines. COGA, CPC, and other industry representatives led the opposition, arguing that “energy is the cornerstone of [the state’s] prosperity” (Glick and Ray 2017)—overstating the industry’s economic importance while ignoring the value of keeping children safe. An investigative report put oil and gas industry clout into some perspective: “Most of the people who testified in favor of the school setback bill were residents. . . . Virtually all who opposed it were paid lobbyists, most from industry associations” (Glick and Ray 2017).
:{
}:
With the passage of Senate Bill 181 in 2019, the state got serious about tightening health and safety controls on the oil and gas industry. The industry, which aggressively opposed the bill, lobbied successfully for a late language change that weakened the ability of local governments to protect public health and safety. At the behest of industry lobbyists, the terms “necessary Union of Concerned Scientists | 9 and reasonable” were added as qualifiers to the bill’s text, potentially limiting the ability of cities and counties to require new protective measures (Bloom 2019)....
Overwhelming Public Voices to Thwart Ballot Initiatives
In 2016, aggressive campaigns by Protect Colorado and Coloradans for Responsible Energy Development (CRED)—front groups funded by API, CPC, Noble Energy, and Occidental Petroleum—prevented two grassroots-driven ballot measures from getting in front of voters (Dyer 2016a). One measure would have increased local control over oil and gas expansion, with the aim of putting science at the forefront of decision-making on siting, reporting, and safety requirements designed to protect the communities.
The other measure would have improved community health and safety by requiring fracking operations be set back 2,500 feet from any occupied structure (homes, schools, businesses) or “areas of concern” (drinking water sources, lakes, parks). The current scientific consensus is that a setback of 2,000 to 2,500 feet is needed to protect health and safety, especially that of children (Lewis, Greiner, and Union of Concerned Scientists | 10 Brown 2018; Milton et al. 2014; McKenzie et al. 2012). The setback would have reduced exposure to air and water pollution, lessened noise pollution, and kept children further from potential explosions. Opponents outraised proponents by a ratio of 24–1, with 99.9 percent of the opponents’ nearly $17 million total coming from energy industry companies or front groups; their campaign drowned out the public health and safety arguments at the heart of initiative (Table 1) (Blake 2016; Claypool 2016)....
,,,Protect Colorado repeated the play again two years later, in 2018, spending almost $40 million to oppose Proposition 112 (Sirota and Woodruff 2018b), which would have required new oil and gas development projects to be set back 2,500 feet from occupied buildings and other areas of concern. In addition to donating millions of dollars to Protect Colorado PAC to opposeProposition 112, Noble Energy directly funded spots on at least 12 TV stations in the month before the election (Sirota and Woodruff 2018b). One ad explicitly told voters: “When you vote, we need your support to stop Proposition 112, so we can continue producing the natural gas and oil that power our daily lives.”
This ad ignored the initiative’s health and safety intent, instead advancing a bogus economic argument that stronger protective measures would put the industry out of business (Sirota and Woodruff 2018a). In 2020, the industry poured money into ad campaigns even with no initiatives on the ballot or legislation in the works. Protect Colorado spent hundreds of thousands of dollars on a statewide online and TV ad campaign aimed at Governor Polis and the COGCC, threatening to challenge any new regulations, particularly on siting setbacks, that the industry deemed unreasonable(Bunch 2020). The industry promoted 500-foot setbacks—about one-fourth the distance that scientists say is best to protect communities, especially vulnerable populations (Lewis, Greiner, and Brown 2018; Milton et al. 2014)....
[rev dr]
Using Proxy Groups to Confuse the Public and Undermine Support for Climate Accountability Lawsuits
In 2018, Boulder and San Miguel counties and the city of Boulder sued ExxonMobil and Suncor, arguing that the companies violated state law by deceiving the public about the dangers of their fossil fuel products. These local governments are demanding that the companies pay their fair share of remediating climate damages accruing in their communities (Boulder County, n.d.; City of Boulder, n.d.;EarthRights International, n.d.; San Miguel County, n.d.).
Almost immediately, ExxonMobil and Suncor launched a counteroffensive, using proxy groups to distort the public’s understanding of the case.The defendants, falsely suggesting that the local governments were seeking a back-door path to achieve legislative goals, attempted to redirect attention away from the on-the-ground reality that communities face budget-busting expenses due to climate change-related fires, flooding, bad air quality, and extreme heat.Industry PR companies, particularly Western Wire (an ExxonMobil executive serves on its board of directors) and Energy In Depth (a project of the Independent Petroleum Association of America), ramped up their substantial media buys to discredit the legal strategy (EarthRights International 2018).
Industry groups also attacked and attempted to discredit a public forum at the University of Colorado Law School on holding fossil fuel companies liable for climate change harms in the state (MAP 2019; University of Colorado Law School 2019). Further, their representatives posed as journalists to try to interview plaintiff’s attorneys outside of appropriate court channels (EarthRights International 2018; EarthRights International 2019). For more than three years, the defendants have used procedural tactics to keep this case—like other recent climate accountability complaints against fossil fuel companies—from being considered on its merits....
Chapter 3 Disinformation Tactic:...