environment | Northwest Coast Energy News

As Joint Review deadline looms, more complaints about lack of information for the public

Energy Environment

Environmental groups are saying that the Northern Gateway Joint Review Panel and Enbridge haven’t given the public enough notice that the Thursday is the deadline for registration to participate in the hearings, which begin in January.

In Smithers, Pat Moss, with the Friends of the Wild Salmon says neither the
National Energy Board, or Enbridge had done much to let people know they
need to register this far in advance.

In Kitimat, Douglas Channel Watch distributed a leaflet door to door warning about the pending deadline.

Those who wish to make oral statements have until October 6 to apply to make an oral presentation to the Joint Review Panel. Applications can be made on the JRP website:

While the hearings are scheduled to begin on January 10, 2012, locations are still uncertain. The JRP website says

Have you made a decision on specific hearing locations?
No. Based on the comments received, the Panel intends to conduct oral hearings in locations close to the pipeline and marine components of the project. The list of oral hearing locations will be announced at a later date.

Moss says this lack of firm dates and locations for those hearings is likely a hindrance to some people who wish to participate, since they cannot know this far in advance where they will be when the hearings come to their area, “We’re very concerned that there
will be a lot of people who will only realize that the hearings are
being held much later, after the National Energy Board announces the
locations and dates for the hearings, and by then it’s long after the
deadline,” Moss says.

The environmental groups say the Joint Review Panel should have had a more aggressive campaign in newspapers, online and in the broadcast media to make people in northern BC aware of the looming deadline.

Wild salmon rivers should be considered ‘no-go zones’: Sun op ed

Environment Opinion Link

Wild salmon rivers should be considered ‘no-go zones’

Nikki Skuce a senior energy campaigner at ForestEthics and Karen Tam Wu a senior conservation campaigner at ForestEthics write in a Vancouver Sun opinion piece:

India has created “no-go zones” for coal mining. These areas are
forests and other ecosystems that have been set aside for protection
from coal mining.

When it comes to energy development in this province,
we should be looking at something similar.In the northwest of the
province, three major wild salmon rivers are born – the Skeena, Stikine
and Nass. These critical watersheds are known as the Sacred Headwaters.
The vast alpine landscape, territory of the Tahltan First Nation, is
also home to grizzly bears, caribou and moose. There are very few places
of its kind left in the world.

We’re not afraid of Kitimat, Oregon rivals say, as papers filed for LNG export terminal permit

Energy

The Jordan Cove Energy Project, often cited by energy industry experts as Kitimat’s chief west coast rival as a liquified natural gas export project, sent a $50 filing fee to the United States Treasury on Friday, thus notifying the US Federal Energy Regulatory Commission that the company is seeking to export liquified natural gas from its planned $3.5 billion terminal at Coos Bay, Oregon.

Although testimony at June’s National Energy Board hearings cited Coos Bay as a rival that could take LNG business away from Kitimat, the view from Oregon appears to be just the opposite.

Jordan Cove project manager Robert Braddock told the industry newsletter, Platt’s Gas, that he is “not afraid of competition from the north, where Kitimat LNG is planning an export terminal in British Columbia. ‘We actually presume that Kitimat would be built,” Braddock said. “We assume that we would be built number two and we think there is plenty of room for two such facilities on the West Coast.’

Braddock also told Platt’s that Oregon is not a rival for BC or Alberta gas nor competition for LNG terminals in Louisiana and Maryland. “The principal difference is we have access to a different range of resources from both Canadian gas and US gas. But equally important is we would have certainly much closer access to the Asian markets,” he said.

The Oregonian newspaper reported that prospective customers in Asia for the Coos Bay project may be waiting to see what happens in Kitimat before signing on with Jordan Cove. Braddock told the Oregonian that the company “is still testing the waters with potential customers, and won’t go ahead with the expensive and byzantine permitting process without firm commitments from terminal users.”

The pro forma initial application filed Friday informs the US Department of Energy that company wants to export up natural gas to countries that have a free trade agreements with the United States. Similar to the National Energy Board hearings on KM LNG, the Federal Energy Regulatory Commission must now hold hearings on the export licence application.

In another similarity, a few years ago, the Kitimat plans called for an LNG project to import gas. Jordan Cove received approval in 2009 to build a terminal to import LNG and to build a 370 kilometre (280 mile) pipeline that would carry the gas to Malin, Oregon, on the California border.

If the US Department of Energy approves the new application, the terminal would become an export, not an import, facility.

In another parallel with Kitimat, like the Enbridge Northern Gateway Project bitumen export proposal, the Coos Bay project has prompted stiff opposition for years. The Oregonian reports “landowners and environmentalists in the region mounted a fierce campaign to block three proposals to build LNG import terminals in Oregon, including the one in Coos Bay,” in the belief that the terminals and associated pipelines would harm forests, farms and salmon habitat. The newspaper also says that local business groups and unions have supported the import projects, which would bring jobs and tax revenue.

An environmental lawyer, Susan Jane Brown, a staff attorney at the Western Environmental
Law Center, told Platt’s Gas she is still digesting the news, but that said the export
plan will likely rankle her clients, environmental organizations and
landowners. “It would be one thing to
import a good that would be used domestically. But exporting a
domestic product that they have long advocated that we need
domestically, it is a bait and switch,” she told Platt’s.

A powerful local politician, Senator Ron Wyden, an Oregon Democrat is skeptical of the idea of exporting LNG from the US and told the Oregonian: “I think it’s premature to conclude that the United States now has so much natural gas that it can afford to export it overseas…I think there ought to be a time-out on approving LNG exports until there is a better understanding of how much natural gas there is, whether it can be safely extracted, and what the impact on the U.S. economy would be from LNG exports.”

Sen. Wyden’s opposition is in stark contract with the various consultants and economists who testified at the Kitimat hearings in June which envisioned a totally integrated North American natural gas marketplace with pipes snaking all over the continent delivering the cheapest and most convenient gas to the nearest market. Wyden’s remarks may be an indication that American politics could put the break on the ideal free market visions of the experts that were expressed before the NEB.

Similar to plans to take shale gas from the Horn River Formation in northeastern BC, Jordan Cove would tap into the Ruby Pipleline, a 1,000 kilometre (680-mile), 42-inch diameter that would carry shale gas from the Rockies to a hub in Wyoming and then to Malin, Oregon to connect with the Jordan Cove pipeline there.

Natural Resources minister Joe Oliver continues to push Northern Gateway

Energy Links

Conservative Natural Resources Minister Joe Oliver is continuing to promote the Enbridge Northern Gateway pipeline. In a speech to the Canadian Club in Toronto, Oliver promoted both the Keystone XL pipeline from the Alberta oil sands to Texas and the Northern Gateway pipeline through Kitimat.

The Globe and Mail reports in New pipelines crucial to expand energy exports: Minister

Canada needs projects like Enbridge Inc. Northern Gateway pipeline to provide crucial access to growing markets for the country’s energy exports, says Natural Resources Minister Joe Oliver.

In remarks prepared for a speech Friday in Toronto, the Minister said the federal government would respect the regulatory review now being conducted on the Gateway project. But he made it clear Ottawa supports the construction of oil pipelines to the west coast, despite opposition from environmental groups and First Nations…..

Projects such as the proposed Northern Gateway Pipeline would connect Alberta’s oil sand to the port at Kitimat on the coast of British Columbia, where tankers could transport oil to Asian customers.”

While he said the government respects the regulatory process, he added: “It is a key strategic objective to diversify our customer base” beyond the U.S., which now accounts for 97 per cent of Canada’s oil exports.

The Associated Press also covered Oliver’s speech, as published in the Washington Post:

Canada’s natural resource minister says the country needs Enbridge’s proposed Northern Gateway pipeline to the Pacific coast to be built so that it can diversify its energy exports to China.

Natural Resource Minister Joe Oliver noted in a speech Friday that the U.S. is basically Canada’s only energy customer. Oliver says it is a key strategic objective to diversify the customer base.

But Aboriginal and environmental opposition to the Pacific pipeline is fierce. The opponents fear it will leak. The local member of Parliament, Nathan Cullen, has said accidents are inevitable in the rough waters around Kitimat, British Columbia, where the pipeline will end. And no one has forgotten the Exxon Valdez oil spill of 1989, some 800 miles (1,300 kilometers) north of Kitimat….

Sinopec, a Chinese state-controlled oil company, has a stake in a $5.5 billion plan drawn up by the Alberta-based Enbridge to build the Northern Gateway Pipeline from Alberta to the Pacific coast province of British Columbia.

Natural Resources Canada news release: Minister Oliver Touts Canada’s Energy Resources and Economic Strengths

Review: Pipeline to prosperity or channel to catastrophe? Globe and Mail

Energy Pipeline Review

Pipeline to prosperity or channel to catastrophe?

The Globe and Mail publishes an essay by Alberta author Chris Turner, author of The Leap: How to Survive and Thrive in the Sustainable Economy.

The essay appears, on the surface, to be an even handed look at the Northern Gateway Pipeline, balancing the environmental concerns with the economy.

In the end, however, Turner sides with where he lives, the province of Alberta, and his compromise could be the destruction of an area that is a thousand or so kilometres from his home.

There’s a more recent Canadian tradition, though – the one that celebrates moderation, fair play, stewardship and compromise. It gave rise to the national parks, land-claims tribunals, Nunavut, Greenpeace and the Montreal Protocol. It argues that Canada can do more with its natural abundance than extract, export and exhaust it at maximum speed. When Enbridge touts its pipeline-safety measures and marine stewardship – the double-hulled boats, the master mariners tugging the tankers carefully past Great Bear’s salmon streams – it is sincerely attempting to participate in that vision.

Yet sincerity is not the same as authenticity. Avoiding an oil spill is not a substitute for reducing greenhouse gases. The conversation has skipped ahead a generation while Canada slept. Catching up could begin with the simple agreement that the wild land of the spirit bear is no place for pipelines – but also that there will probably be a place for pipelines, at least for the near term. But that would be just the start of an honest discussion of Canada’s uncharted energy future.

For the long term health of the planet, reducing greenhouse gases is vital for the preservation of our current civilization.

For Turner, in the end, the old argument prevails, what is good for Albertans is good for the rest of the country, Alberta=Canada.

There is little doubt that the current management of Enbridge and Northern Gateway is sincere in their efforts, or as sincere as an energy company can be. Unfortunately there is no guarantee that subsequent management will care as much after the approvals are signed and sealed and the pipeline is built.

Apart from those who may actually work for Enbridge if there is an oil spill in the future, Albertans will be able to drive into the wilderness and enjoy the Rockies while, if there is a spill, the salmon, halibut, seals, whales, eagles, gulls, grizzlies, black and kermode bears, not to mention the residents of the northwest First Nations who have been here for thousands of years and the relatively recent non-aboriginal residents will be left to clean up the mess and pay for that cleanup, while Alberta continues to prosper.

Harper’s decision to defund coast management group may blow back on Enbridge, lawyer says

Energy Environment Link

The West Coast Environmental Law blog says the decision by Prime Minister Stephen Harper to take funding away from the Pacific North Coast Integrated Management Area plan may actually blow back on Enbridge, delaying the Northern Gateway pipeline project for years.

The cancellation of the funding is perceived as part of the Conservative government’s aim of pushing the
Northern Gateway pipeline through no matter what the cost. (Two cabinet ministers, Joe Oliver and James Moore are publicly endorsing the Northern Gateway, despite the fact the Joint Review Hearings don’t even begin until January 2012. It is unlikely either minister would make an endorsement like that without Harper’s approval.)

In the blog post, Why Harper’s shot at PNCIMA also hit Enbridge in the foot, lawyer Andrew Gage argues that Harper’s move, apparently motivated by fears that the PNCIMA process could block the pipeline, fears created by Vancouver blogger Vivian Crause and her allies among PostMedia’s right wing columnists, will actually delay the pipeline for years because it negates the legal obligation to consult First Nations and thus will likely throw the entire process into the courts for years.

Litigation by any of the Coastal First Nation against the Enbridge Pipeline could pose a serious problem for Enbridge and its Northern Gateway Project. Because of First Nations title and rights that are protected by Canada’s constitution, the federal government has a duty to “act honourably” and to consult and accommodate First Nations who have a “credible but unproven claim” of rights that may be adversely affected by a government decision (such as approving the Enbridge Northern Gateway Pipeline project and related tanker traffic.)

As a result, anything that the federal government does in relation to consultations with the Coastal First Nations about tanker traffic and the Enbridge Pipeline that might be considered “dishonourable” creates legal uncertainty and problems for Enbridge. So was the decision to withdraw from the current PNCIMA funding arrangement “dishonourable?”

Gage notes that the federal government is required by the Oceans Act, passed under the Liberals in 1997, to set up integrated management plans for all coastal areas of Canada, not just the northwest, a process that began in 2005.

Gage also points out that Enbrige has, in the past, participated in the process:

A wide range of stakeholders, including one seat for the conservation sector, provide input and consensus based advice on an Integrated Oceans Advisory Committee, but do not determine the outcomes of the PNCIMA process. Enbridge has itself participated on the Integrated Oceans Advisory Committee, along with representatives of the fish farming, commercial fishing, renewable energy, recreational fishing and tourism industries, and even sponsored an early workshop in the PNCIMA process.

In short, PNCIMA is created by the federal government, managed jointly by the federal and provincial governments and First Nations, but with efforts being made to involve a wide range of stakeholders. Because the PNCIMA is co-chaired by a federal government staff-member, and requires sign-off from the government, it was unlikely to have resulted in a complete ban on oil tanker traffic, although it might have placed restrictions on marine travel, or otherwise provided protection for the coast from shipping impacts.

However, progress was slow, in part due to the limits of federal funding available for the process.

He goes onto to say that the Harper government itself agreed to the now controversial foundation funding in 2010. That was before the attacks from Crause and the PostMedia’s business columnists reached a crescendo in recent weeks. But now there is no longer any mechanism that can be perceived as neutral that consult with First Nations and other northwest coast stake holders.

To flip-flop now, slightly more than a year before the process was supposed to wrap up, leaves the PNCIMA process without the funding that the government has acknowledged is required for a thorough planning process. It is also a slap in the face for the Coastal First Nations, the BC government, environmental organizations and industry stakeholders who have worked on this process for years.

Prime Minister Harper’s government may have believed that it was helping Enbridge and its Northern Gateway Pipelines by withdrawing from this funding agreement. But the resulting uncertainty, and the appearance that the federal government has acted less than honourably towards the Coastal First Nations, may well cause Enbridge huge legal head-aches in the future.

Editor’s note: As I said in this post, there appears to be a double standard, since what the Harper government, PostMedia’s columnists and Krause apparently are saying that it is only acceptable if billionaire capitalists spend their money on a conservative or pro-energy industry agenda, but it is not acceptable if a billionaire capitalist decides to spend his money to protect the environment.

Salmons’ extra large guts are a survival tactic

Image via Wikipedia

Environment Fishery Science

Salmon have extra large guts–up to three times larger than its body would suggest–that help it survive, scientists at the University of Washington say.

The study “Excess digestive capacity in predators reflects a life of feast and famine” is published in Nature.

A news release from the university calls the large gut a “previously unrecognized survival tactic.” Although fishers who gut a salmon may say that no one noticed how big the gut actually was as they threw it away, the same apparently applied to scientists as the article states: “Despite …basic principle of quantitative evolutionary design, estimates of digestive load capacity ratios in wild animals are virtually non-existent.”

The study is by PhD student Jonathan “Jonny” Armstrong, originally from Ashland, Ore, who says he has been fascinated by salmon ever since he saw a Chinook leap out of the water when he was ten.

The study says that when the “foraging opportunities for animals are unpredictable, which should favour animals that maintain a capacity for food-processing that exceeds average levels of consumption (loads), The study that piscine [fish] predators typically maintain the physiological capacity to feed at daily rates two to three times higher than what they experience on average…”

“This much excess capacity suggests predator-prey encounters are far patchier – or random – than assumed in biology and that binge-feeding enables predators to survive despite regular periods of famine,” Armstrong said. Co-author and supervisor on the paper is Daniel Schindler, University of Washington professor of aquatic and fishery sciences.

“Guts are really expensive organs in terms of metabolism,” Armstrong said. For instance, maintaining a gut can require 30 to 40 per cent of the blood pumped by an animal’s heart.

Some animals have some capacity to grow or shrink their guts in response to changing conditions. For example, according to previous studies, the digestive organs of birds that are about to migrate expand so they can eat more and fatten up. This is followed by a period when their guts atrophy and then, freed of the baggage of heavy guts, the birds take off. But this study shows that many fish species maintain a huge gut, which enables them to capitalize on unpredictable pulses of food.

Ravens and crows, for example, are known to cache food far from where they find it. Fish can’t do that. “Unlike some other animals, fish can’t just hoard their food behind a rock in the stream and eat it later. They need to binge during the good times so that they can grow and build energy reserves to survive the bad times,” Armstrong says.

Armstrong is part of the university’s School of Aquatic and Fishery Sciences which has a field site at the Alaska Salmon Program’s Lake Aleknagik. Using a dry suit, Armstrong snorkeled the Aleknagik tributaries, swimming in waters as low as 5°C where he found out the Aleknagik streams exhibited tremendous variation in water temperature, which inspired him to study how those temperatures affected the ecology of the streams.

In his initial studies, he looked at the effect of water temperature on juvenile coho’s ability to consume sockeye eggs. He says, “In cold streams, juvenile coho salmon were too small to fit the abundant sockeye eggs in their mouths. In warmer streams, the coho grew large enough to consume eggs, gorged themselves, and achieved rapid growth, and this suggested that small changes in temperature can have disproportionate affects on coho salmon production.”

The “previously unrecognized survival tactic” might apply to other top predators, such as wolves, lions and bears, Armstrong says.

Kitimat takes halibut fight to BC municipal convention

Environment Fishery

District of Kitimat councillor Randy Halyk, seen here at the local Jack Layton memorial on August 27, 2011, will be defending Kitimat’s resolution on halibut quotas at the Union of BC Municipalities convention. (Robin Rowland/Northwest Coast Energy News)

Kitimat is taking the fight over halibut allocation to the Union of British Columbia Municipalities convention to be held in Vancouver September 26 to September 30.

The resolution is one of two that the union will consider on the halibut controversry, the other comes from the Capital District on Vancouver Island,

Members of the District of Kitimat council will be at the convention to sponsor and defend the resolution.

The Kitimat resolution calls on the union to endorse:

Whereas the current federal allocation of the sustainable Pacific halibut resource is insufficient to provide reasonable catch and possession limits for the recreational and commercial sport fishery;

And whereas an increase in daily catch and possession limits would be of great benefit in attracting sports fishing tourists to coastal communities.

Therefore be it resolved that the UBCM support an increase in the allocation of the sustainable Pacific halibut resource to the sport fishing and requests that the federal Ministry of Fisheries and Oceans increase the catch limits to two per day and four in possession.

The Kitimat resolution was endorsed by the North Central Local Government Association

The overall province wide resolutions committee gave no recommendation on the Kitimat resolution saying it wasn’t clear what impact the resolution would have on the sports fishing industry. The committee added a note to the agenda that in 2010 members of the UBCM did endorse a resolution that requested the provincial and federal governments support both the commercial fishing industry and the sports fishing industry equitably as they are both critical economic generators for residents within the province.

The resolutions committee notes that British Columbia did express “support for the sustainability of both commercial and recreational fisheries in tidal waters.” The province apparently “highlighted a number of its activities related to ensuring fisheries sustainability and maximizing the economic and social benefits.”

The somewhat stronger resolution from the Capital Region did not receive an endorsement from the Association of Vancouver and Coast Communities and a “no recommendation” from the province wide resolution committee. That resolution says, in part that the allocation between the recreational and commercial sectors in the Canadian halibut fishery during years of low abundance will destroy the economic viability of coastal communities and deny Canadian citizens access to the common property resource of halibut.

It calls for a “more fair and equitable approach that would allow the recreational and commercial fishing industries to survive during years of low annual quotas,” it calls for the federal government to purchase or lease halibut quota from the commercial sector (rather than having the recreational sector purchase individually as the current Department of Fisheries and Oceans “pilot project” calls for) so that the recreational sector has a “permanent base limit,” that the season be guaranteed from February 1 to December 1 each year and that the limit be one halibut per day, two in possession. (The Department of Fisheries and Oceans stopped the recreational halibut season as of midnight Sept. 15 while allowing the commercial season to continue).

Harper kills bitumen export ban, support for ocean monitoring group: reports

Energy Links

According to media reports, Prime Minister Stephen Harper has killed support for the Pacific North Coast Integrated Area Management Initiative (PNCIMA) set up to monitor the ocean on the northern BC coast, while at the same time killing a plan to ban export of bitumen to countries with poor environmental records.

The Calgary Herald, in Harper backs off from initiative that threatens opposition to Northern Gateway pipeline

Prime Minister Stephen Harper’s government has withdrawn support from a deal with the B.C. government and First Nations due to concerns about excessive influence by U.S.-funded environmental groups in the development of an oceans management plan for the B.C. north coast….

There were specific concerns that a new plan being developed under the Pacific North Coast Integrated Area Management Initiative (PNCIMA) could be used to rally opposition to Calgary-based Enbridge Inc.’s proposed $5.5-billion Northern Gateway pipeline that would funnel diluted bitumen crude from Alberta’s oilsands sector to Asian markets docking at Kitimat, B.C.

A letter dated Sept. 1, and sent to the B.C. government, three First Nations groups and the environmental organization Tides Canada, said Ottawa is withdrawing support for a proposed agreement that would have resulted in $8.3 million, from the Gordon and Betty Moore Foundation of Palo Alto, California, to fund the PNCIMA process.

The letter, from Fisheries and Oceans Canada regional director general Susan Farlinger, said the government still intends to come up with an oceans management plan by 2012 in co-operation with B.C. and First Nations.

The Vancouver Sun reports Conservatives’ promise to restrict bitumen exports falls by wayside

The Harper government has quietly buried a controversial promise to ban bitumen exports to countries that are environmental laggards…

One person familiar with Prime Minister Stephen Harper’s surprise announcement during the 2008 federal election campaign said the pledge was simply electioneering at the time and was to be “buried and never seen again.”

Alberta’s energy minister also wonders whether the campaign promise is even a government policy any longer, noting the issue has never been discussed with him during his two years in the portfolio.

However, a spokeswoman for federal Natural Resources Minister Joe Oliver said Wednesday the government policy — designed to halt the flow of raw bitumen and jobs overseas — remains in place but is being regularly examined.

Link Pacific North Coast Integrated Area Management Initiative

Editor’s note:A double standard?

On the issue of the PNCIMA, the controversy is over money for the organization from the foundation set up by the founder of Intel, Gordon Moore.

Moore is famous not only for starting the successful chip company but for Moore’s Law, which has governed the accelerating pace of technological change in the past decades and is described by Wikipedia in Moore’s original formulation: “The number of transistors that can be placed inexpensively on an integrated circuit doubles approximately every two years. This trend has continued for more than half a century…” That simply means that computer processing power can be expected to double every two years.

The Gordon and Betty Moore Foundation, according to the Herald, called for the money to be channeled through a group called Tides Canada.

Support for Canadian environmental efforts by American foundations has long been the subject of a heated campaign by blogger Vivian Krause who told the Herald, “I’m pleased that taxpayers’ money will no longer further a foreign-funded campaign that is against Canadian interests,” Krause said, adding that foundation money should go to the developing world.

Krause says she is an independent commentator. She once worked as Corporate Development Manager for North America for NUTRECO, one of the world’s largest producers of farmed salmon and fish feed but disassociates herself from current public relations campaigns by the fish farming industry. Her online biography says she spent some part of her childhood in Kitimat.

Krause is a favourite of many of the right wing columnists across the PostMedia newspaper chain.

While Krause may have some valid points, one wonders why for Krause and her supporters on the business pages across Canada, that it is perfectly acceptable for the billionaires in the transnational energy industry, many of them American, (as well as the state owned Chinese energy companies) to spend corporate millions supporting the oil sands and the pipelines, while is not acceptable for another American capitalist billionaire to spend his money earned in the free market to support his views on the preservation of the environment.

Links: More objections to halibut closure

Environment Fishery Links

Letters and op ed opinions to various media continue, objecting to the early closure of the recreational halibut fishery.

Courier Islander
Robert Alcock

Halibut decision hurts economy, communities

While this decision will have a substantial impact on the economies of
hundreds of businesses and dozens of coastal communities that depend on
the recreational halibut fishery for economic activity, it might be
understandable if commercial quota holders were actually required to
utilize their licences and quota shares.

Northern View

Bruce Wishart

DFO fails Canadians with closure of the Halibut fishery

Even before the closure, DFO stopped a lot of people from booking trips this year by announcing their intent and creating massive uncertainty. DFO created this allocation system. They had no idea how it would work. They didn’t allow for growth, and they didn’t even have accurate information to begin with. They’ve created a situation where a publicly-owned resource is being bought and sold by private interests. None of it made any sense to begin with – as just one example, when the sport fishery didn’t catch their allocation the commercial fishery was allowed to fish it, but the reverse was not allowed.