Monday, June 8, 2009

It's an interesting trip, following the money...

By Ed Zieralski
San Diego Union-Tribune

These days, partnerships involving government and private groups for fish and game issues are leading to some pretty strange bedfellows.

But none is stranger than the one forged recently by the California Department of Fish and Game and the Humane Society of the United States.

The DFG uses hunting as a game management tool. It uses hunting and fishing license and tag fees and some taxpayer money to do its work. The Humane Society fights for animal rights. It survives on donations from a mostly anti-hunting constituency.

But the Humane Society has given the DFG $5,000 for food and veterinary care for its five rescued dogs that will assist wardens in catching poachers in its Turn in Poachers program (CalTIP), and another $2,500 for reward money toward CalTIP.

I can't fault the DFG for accepting money right now, even from the anti-hunting Humane Society, to help offset expenses or improve the overwhelmed wardens' working conditions. We may as well get used to partnerships like this, considering California's sorry economic state.
In fishing, we're watching as anti-fishing, extreme environmentalists are funding most of the Marine Life Protection Act process.

The Resources Legacy Fund Foundation (RLFF) has contributed over $18 million of the $34 million it has cost to run the MLPA process to date. RLFF is funded largely by the Packard Foundation, which funds the Monterey Bay Aquarium and many ocean protection programs that are no friend to fishing.

Fish and Game Commissioner Michael Sutton, who votes on the MLPA, is being investigated for conflicts of interest by the Fair Political Practices Commission because of his ties to the Packard Foundation, which is funding the RLFF and gave money to the Monterey Bay Aquarium, where Sutton is an officer.

But the anti-fishing folks are smart. The RLFF also contributed hundreds of thousands of dollars to pro-fishing groups like United Anglers and the Fishing Information Network – the latter a group of commercial and sport fishers who are fighting the anti-fishing groups in the MLPA process. Tom Raftican, the former head of United Anglers of Southern California, was forced to resign because he was sounding more like a preservationist than a conservationist after taking hundreds of thousands of dollars from the RLFF for his group.

Bob Osborn represents United Anglers on the South Coast Regional Stakeholder Group and is having his expenses paid by RLFF money to be at the MLPA meetings. Other fishing reps are, too.

Just this past Thursday at the Blue Ribbon Task Force meeting in Los Angeles, Ken Wiseman, executive director of the MLPA-Initiative staff, berated fishing representative Vern Goehring for criticizing special-interest funding of the MLPA process. Wiseman appeared to take great pleasure in reminding Goehring that the RLFF gave the Fishing Information Network (FIN) money to help produce its External Proposal A for marine protected areas.

The bottom line is, for some time, United Anglers, FIN, DFG and others have been on the slippery bank of taking money from the very people they fight for access, for rights.

Like the cockroach and the coyote, the MLPA will still roll even after the governor cuts programs for kids, the poor, schools, state parks, fishing and boating.

That's what $18 million (and likely a lot more) bought the RLFF and the anti-fishing groups from this administration and the faces we don't see.

The Humane Society's buy-in is a pittance compared to that.

Friday, June 5, 2009

MLPA Initiative a Schwarzenegger priority, budget woes notwithstanding

LA Times

Reed Smolan unhooks a calico bass caught off the Palos Verdes Peninsula. A portion of ocean beyond the peninsula faces possible closure as part of the Marine Life Protection Act Initiative. For those wondering whether California will follow through with the Marine Life Protection Act Initiative in light of the state's massive budget deficit and the drastic cuts being made elsewhere, the answer appears to be a resounding yes.

Natural Resources Secretary Michael Chrisman on Monday delivered a memo to the California Fish and Game Commission in response to two commission members who recently suggested a delay in further implementation of the MLPA process. The MLPA Initiative staff and stakeholder groups are working toward establishing a coastwide network of marine protected areas -- which would be off-limits to fishermen -- and is currently focusing on Southern California.

Chrisman explained to the commission, on behalf of Gov. Arnold Schwarzenegger, that "California's process for adopting an improved system of marine protected areas is well funded. Moreover, there is no reason, funding or otherwise, for the process supporting the law to be postponed."

Chrisman further explained that the state budget has "consistently provided support for MLPA" and that "this funding is but a small part of the more than $34.2 million that has been allocated statewide for MLPA by a partnership of state agencies and foundations."

This news will be disappointing to many fishermen but should be reassuring to environmental groups that favor a network of no-take areas to benefit beleaguered stocks of fish, and that have devoted thousands of hours, as stakeholders, to the painstaking process.

-- Pete Thomas

Photo: Reed Smolan unhooks a calico bass caught off the Palos Verdes Peninsula. A portion of ocean beyond the peninsula faces possible closure as part of the Marine Life Protection Act Initiative. Credit: Pete Thomas / Los Angeles Times

Wednesday, June 3, 2009

Fish and Game Commissioner Dan Richards disappointed in Ken Wiseman and Don Benninghoven

June 2, 2009
Fish and Game Commissioner Dan Richards is not happy with the latest developments in the South Coast project area in the Marine Life Protection Act Initiative and comments by Resources Agency officials about the next region, the area north of Point Arena to the Oregon border, due to begin meeting this fall.
Although Ken Wiseman and initiative staff just today (June 2) have retracted the decision to forward external proposal C despite the fact it was voted out (see the memo attached to the bottom of this blog), the fact that he and Blue Ribbon Task Force Chair Don Benninghoven would consider such a move in the first place has shaken not only stakeholder confidence in the process, but Richards’ as well.
Richards’ contacted this writer yesterday, just as we were sending the latest issue of WON to the printer, but his comments were both prescient and significant.“
Although I don’t know if this decision will stand, I am so disappointed in Ken Wiseman and Don Benninghoven,” said Richards. “They’ve been standing up talking about what an open and transparent process this is and then they take an action like this. I never knew they had the power to unilaterally change the vote, who gave them that?
“What’s the point of the vote, what’s the point of participating? I’m sure there are a lot of stakeholders asking that question,” he added. “Why don’t Ken and Don just send us (the Fish and Game Commission) something up and say this is what it should be, these people don’t know what’s right, but we do?”
Some stakeholders would argue that’s exactly what has happened in the previous two projects — the Blue Ribbon Task Force deciding what is best instead of the stakeholders.
And others would say the Fish and Game Commission, which is the only entity in California government with the power to close state waters, has just been a rubber stamp at the end of the process.
Richards is one of the commissioners who bristle at that suggestion. He and Commission Jim Kellogg have been outspoken about making sure the state and the economy can bear the cost of the closures.
He took particular exception to a recent comment made by Sandy Cooney, a spokesperson for California’s Resources agency, in the Eureka Times Standard. The story was about how the Humboldt Bay Harbor, Recreation and Conservation District was considering asking for a delay in the process until good science is in place. Sound familiar? Here’s the part of the piece that got Richards steamed.
California Resources Agency spokesman Sandy Cooney said that a delay “is not going to happen.”
He said the act is law, and that the marine protected areas will be put in place on schedule. The state and its private partners have so far put up $60 million in the central and north central coast for science to back up the reserves, Cooney said, and there will be money available for the North Coast, too. Cooney chafed at the idea that communities have had reserves imposed on them.
"No one is being steam-rolled at all,” Cooney said, “It is one of the most open and inclusive processes we have going.”
“How does he know there’s not going to be a delay?” asked Richards. “Where does he come up with $60 million? And how does he know the marine protected areas will be put in place on schedule. Does he have a vote? Last I checked only the Fish and Game Commission can vote in a marine protected area. Does he have the names of three commissioners who will guarantee they will vote for the MPAs? And you certainly have to take exception to the statement the process is open after what just happened.”
When contacted by WON, Cooney said the $60 million represented all the money spent on marine protected areas in California since the creation of the reserves at the Channel Islands, but was unable to provide precise figures. Otherwise, Cooney said he would stand by his words.
I don’t know about you, but all of this has left me feeling flat.







Tuesday, June 2, 2009

MLPA process gets more than a little bit fishy, pro-fishing groups claim

Pete Thomas
Los Angeles Times
June 2, 2009



A reader shared an interesting observation this week regarding the controversial Marine Life Protection Act process, an ongoing saga that ultimately will set in place a coast-wide network of zones that will become off-limits to fishermen or carry severe restrictions.
The process is already complete off Central California and is close to being complete off the North-Central Coast. Southern California is now the primary theater.
The reader wondered how California, which is so broke that it plans to cut all core funding for 279 state parks, can afford to continue with a process of establishing underwater parks that will require steady and significant funding for enforcement of rules and to evaluate their effectiveness.

Short answer: The state is receiving private funding for the process and will worry about future funding once the process is complete and no-take zones are in place. And what a crazy process it has become, especially if you're a fisherman or in the fishing industry and facing an uncertain future.

At issue this week, as all parties prepare for another Blue Ribbon Task Force meeting Thursday morning near LAX, is external proposal "C." It's the most extreme proposal (pictured above and below; the red areas are no-take marine protected areas) and probably should have been scuttled by now.
(It may soon be discarded, although most fishermen are not aware of that yet, and they're still seething over what transpired during the last meeting in Santa Ana.)

Briefly put, members of the South Coast Regional Stakeholders Group were instructed to vote on four of five proposals to further narrow options. External C, which calls for 47 marine protected areas or about 33% of the Southern California coastline to be designated as marine protected areas, received the fewest votes.



But the MPLA Initiative's Blue Ribbon Task Force chose to disregard the vote and place all proposals back on the table. It was perceived as a slap to the face of those who had been working within guidelines during a long, arduous process that still has months to play out. The United Anglers charged that if a pro-fishing proposal had received the fewest votes it would have remained shelved. It's not lost on anyone that a conservation organization, the Resources Legacy Fund Foundation, is funding the process.

However, criticism might have gotten to the MLPA Initiative staff. This morning, according to sources inside the process, the staff issued a memo to the Blue Ribbon Task Force, recommending that the vote should be considered and that the external C proposal should be removed from consideration.

If that's true, it's good news for pro-fishing groups. But those groups and irate fishermen are likely to remain suspicious heading into Thursday's meeting. For those interested in attending, it'll be held at 9:30 a.m. at the Sheraton Gateway Los Angeles Hotel, 6101 W. Century Blvd., Los Angeles, CA 90045.

**Special Important Announcement: Critical MLPA mobilization this Thursday June 4th, 2009

Guys and gals,

The MLPA Implementation Team has double-crossed fishermen and other consumptives with their blatant bias for the anti-fishing faction. Ed Zieralski, writer for San Diego Tribune called it “Betrayal at its worst in MLPA process.” Paul Leibowitz, writer for Western Outdoor News, called it “Trust Betrayed.”

These actions gravely endanger the right to fish in Southern California. The next Blue Ribbon Task Force (BRTF) meeting is this Thursday, June 4th, 2009, 9:30AM at the Sheraton Gateway Los Angeles Hotel, 6101 West Century Boulevard, Los Angeles, CA. Fishermen and ocean sportsmen of all stripes are recognizing that unless there is a strong public response with the BRTF, the future of fishing in Southern California is doomed due to the fraudulent manner with which this process is being rammed down fishermen’s throats.

Bloodydeckers are mobilizing along with other consumptive communities to respond. We need to let the BRTF know what we think about the voting shenanigan that allows the anti-fishing map External C to continue after it was voted out by the Regional Stake Holders. We need to go and press our concerns regarding the extreme maps again. Keep pushing for the moderate position to keep our fishing areas open. Keep pushing for minimum closures instead of the extreme and expansive closures proposed by the anti-fishing groups. You can also speak about how closing or keeping a specific area open to fishing will affect you, your family, and friends economically and/or recreationally.

While it may seem tedious to go all the way to LA to attend this meeting, especially during a weekday, your attendance matters a great deal. For example, your attendance and speaking out on May 19th made a tremendous difference and is widely credited with helping to swing the tide in our favor. The fact that the anti-fishing crowd has to resort to voting shenanigans, in order for the extremist's External C map to stay alive, should tell you that your presence and testimony do have a tremendous effect.

Keep in mind that these are the very last chances we have to address the BRTF in this MLPA process. They are the decision makers--the next one is in July and then it's into October. There is a meeting late October but the reality is this one and the July meeting are going to be it for addressing these important decision makers.

Also, while you may feel righteously indignant, please keep in mind to be courteous but firm and professional. Don't blow your top; don't act unprofessional; don't use curse words. Remember that the BRTF is the decision makers in this process, and their decision will affect where you can or cannot fish next year.

The public speaking session starts at 9:40AM but please be present by 9AM at the latest. Comment cards should be filled out and handed in before 9:00 AM as they may limit comments to only those cards received by that time.

Hope to see you there Bloodydeckers!!! Click here for more info about the meeting location and time.

Thursday, June 4, 2009 9:30 a.m.
Sheraton Gateway Los Angeles Hotel
6101 West Century Boulevard
Los Angeles, CA 90045

Monday, June 1, 2009

Marine protection act falls short of its goals

by Steve Scheiblauer
Santa Cruz Sentinel

Californians concerned about protecting our ocean should pay attention to the ongoing Marine Life Protection Act process that's supposed to improve ocean health, biodiversity, and marine ecosystems off the coast of California.

So far, those goals aren't being met.

That's because the implementation of the act has failed to address, much less resolve, longstanding, serious water quality problems, and has simply given the illusion of protection by opting for the low-hanging fruit of shutting down fishing. During the Central Coast portion of this ocean protection process, comprehensive and scientifically based recommendations on how to implement the mandated marine protected areas were effectively ignored.

The way the act was implemented in Monterey illustrates important mistakes that, if recognized by the leadership and corrected, can make the upcoming efforts much more effective in preserving and protecting our ocean.

We all know that people come to Monterey, and many other coastal communities, to eat fresh, locally caught seafood and to enjoy the uniqueness of our fishing culture, like Cannery Row. We have a deep heritage of commercial and recreational fishing, which supports Monterey's larger tourism industry.

But the effort to carve out ocean areas for new fishing restrictions along the Central Coast has unfortunately rejected a comprehensive approach to achieve sustainability goals. The resulting negative impact on the fishing community has made it more costly and dangerous to catch fish. And it's hurt our broader economy at a time when we can least afford it.

In 1995, there were more than 150 commercial fishing boats operating out of Monterey's harbor, but in the last few years, that number has decreased drastically. There are now only about 30 full-time boats and just 73 total. And that number is expected to drop even more.

As Monterey's harbormaster, I've seen firsthand how local fishermen are dispirited -- and even put out of business -- because the implementation process didn't value their needs, their safety, or the food they provide to the public, much less their recommendations for how to achieve ocean protection as well as viable fishing communities.

It's unfortunately amounted to a political process of taking away a large percentage of the prime fishing grounds from recreational and commercial fishermen based on the beliefs of a few marine protection advocates, rather than a need founded in peer-reviewed science or supported by broad-based public opinion.

And the imbalance favoring expansive restrictions remains intact in the guidelines for determining the size and spacing of new marine protected areas.

But that's certainly not what Californians want.

When polled which is the better management strategy -- to set aside some areas and not let people fish in those areas even if it means that fishing is displaced, or to manage all of the ocean for sustainable use through science-based fishing quotas -- by a nearly 3-1 margin Californians select the option for sustainable use of the entire ocean.

That's significant when compared with the way in which the Marine Life Protection Act has been implemented thus far.

California deserves better than this.

The Marine Life Protection Act must achieve a more balanced process, crafting fair, equitable solutions that preserve a balance: healthy oceans, sustainable seafood resources and economically strong coastal and harbor communities. Otherwise we will see a steady destruction of harbor communities, along with our ability to enjoy the ocean and put fresh local seafood on the table.

Steve Scheiblauer is Monterey's harbormaster and has been directly involved each of the state's attempts to implement the Marine Life Protection Act.

Betrayal at its worst in MLPA process

By Ed Zieralski
May 29, 2009

Fishing interests involved in the Marine Life Protection Act process and those following it closely were outraged this week by a decision made by those running the show.

And they all had every right to be outraged and feel betrayed.

As the Marine Life Protection Act, which already has closed key fishing areas along the Central Coast, moves into its next phase here in the South Coast, here's where the process is:

It started on the Central Coast, and that's done, with 85 square miles of the total Central Coast closed, including 40 percent of the best sportfishing areas. Actually, this process of closing waters to fishing began with the Channel Islands in 2002 when 175 square miles of state waters around the Channel Islands were closed. It resulted in an estimated $100 million annual loss to the local economy there. The North Central Coast closures still must be voted on by the Fish and Game Commission. That's expected to happen in August. While the least intrusive and least costly (in terms of economic hardship to fishermen and the community) set of closures in the 2XA proposal make the most sense, the Blue Ribbon Task Force (BRTF), and likely a majority of the Fish and Game Commission, are backing the Task Force's IPA, or "integrated preferred alternative." It's no surprise to anyone that the preservationist-environmentalist community is all-in on that proposal. There's not a huge difference in the two, but it's significant to the fishermen who will be impacted by it. The 2XA proposal calls for 137.1 square miles of marine protected areas, or 18 percent. The Integrated Preferred Alternative calls for 20.1 percent, or 153.4 square miles.

The South Coast part of the MLPA process, the one that covers PointConception to the Mexican Border, is heating up thanks to a crawfish move by the Marine Protection Act Initiative team earlier this week.

I'm calling it a crawfish move because how else to describe the Initiative staff, or I-Team, as it's called, backsliding on its decision to allow the least popular, most polarizing proposal for marine protected areas to proceed to the next round after it was voted off the island?

Without getting too technical, the South Coast Regional Stakeholders Group (SCRSG) was instructed that the list of proposals for marine protected areas had to be "winnowed" in order to get to six.

As we all know, winnow means to separate the chaff from the grain, get rid of or eliminate errors in logic, separate the good from the bad, sift, select the more desirable, all that.

Only six proposals would go forward, the stakeholders were told. Two proposals were formed by a convergence of opposing sides in two of the subgroups (Opal and Topaz) from the main stakeholder group.

So, with those two proposals already set to move forward for scientific analysis and Blue Ribbon Task Force evaluation, the stakeholders were asked to choose four from the five proposals … two proposed by the third subgroup of the stakeholder group and three external proposals from outside interests.

This is where it all turns ugly.

Two of the three external proposals came from fishing groups. External A came from the Fishermen's Information Committee-Fisherman's Information Network (FIC-FIN).
External B was put forth by a fishing organization. External C was proposed by the Santa Barbara Channelkeepers and Santa Monica Baykeepers.

These are estimated figures, but clearly the External C Proposal is the most radical of all the proposals. It riled many of the stakeholders when it was introduced in Long Beach. It has polarized the group ever since.

External C calls for 47 marine protected areas, or 33 percent of the Southern California coastline put in marine protected areas.

External A, the one proposed by FIC-FIN, calls for 40 marine protected areas or just just under 12 percent in marine protected areas.

A straw vote tally was taken.

All 64 South Coast Regional Stakeholder Group members participated in the voting. Opal and Topaz (the two subgroups of the stakeholder group) reached a unified proposal and will automatically move forward for evaluation.

Lapis 1 proposal (representing the preservationists in this subgroup) got 63 votes. Lapis 2 proposal (from the fishing interests in this subgroup) got 61 votes. External A, proposed by the Fishermen's Information Network, was the only proposal to earn a unanimous vote of 64 in favor of advancing. That's 100 percent of the group voting for this proposal.

It couldn't have gone any better for fishing interests.

External B only earned 39 votes.

And last, and certainly least, External C was the worst of the batch, as voted by the stakeholders, earning just 29 votes.

It couldn't have gone any worse for the preservationist-environmental groups. Per the Ć winnowing‰ process ordered by the I-Team, Proposal C, this chaff, was supposed to be separated from the grain. Thrown out. Culled. Filletted.

Instead, by a judgment still unexplained, it lives and now must be analyzed and evaluated like the hard-fought compromised proposals hammered out by the stakeholders.

Ken Wiseman, the executive director for the I-Team, sent the stakeholders a mea culpa explaining why seven proposals will go forward instead of six. He has not returned an email request from the San Diego Union-Tribune to explain why. But the Union-Tribune obtained a copy of his email to the stakeholders. "We have decided that all seven proposals will move forward for analysis and review as part of the Round 2 evaluation process," Wiseman said in his email to all the stakeholders. "This decision was made in the interest of maintaining the maximum confidence in an open and inclusive process, maximizing the amount of information available from the various evaluations, and acknowledging that with the significant stratification of the votes, acting on the vote would have led to the elimination of two draft proposals.

"Moving forward with all seven draft proposals is contrary to what staff indicated would be the result of the vote," Wiseman added. "However, an important goal of the MLPA Initiative is to ensure that all voices in the process are heard and given consideration; doing so both respects the intent of the MLPA and works toward the best cross-interest solution for all Californians. We believe moving all seven draft proposals forward for analysis will help achieve this goal."

Those involved in the process and those watching it closely are riled up about this, and they should be.

"External C is the most radical and least considerate of all the proposals," said Louie Zimm, a member of the Fishermen's Information Network. "The vote was very clear, unanimous. But it's also clear that Ken Wiseman is beholding to the Resources Legacy Fund Foundation that is funding this process. It's clear he felt his very livelihood is threatened by this. It's clear they have to keep in consideration this extremist proposal for marine protected areas to please those funding the process."

Zimm also fired off an email to Wiseman and Don Benninghoven, chairman of the Blue Ribbon Task Force, expressing that he was gratified that External Proposal A, which he helped fashion, was a unanimous choice of the stakeholder group, but how disappointed he was in the I-Team's decision to include External Proposal C in the process after it received the least amount of votes.

"External Proposal C received only 29 votes, less than half of the RSG votes," Zimm told Benninghoven and Wiseman. "This proposal appears to be a somewhat one-sided and myopic proposal. From the onset, with its original iteration, Proposal C has been unrealistic and callous. The authors have not attempted to reach out to opposing interests for compromise.

"I was a steady observer of the Topaz gem group," Zimm continued. "That proposal was the product of heart-felt soul-searching and wrenching compromise. Now that proposal will be put on an equal footing with the unsupported and uncompromising External C proposal. This must certainly be a terrible disappointment to the hard-working members of both Opal and Topaz gem groups who took the I-team's and the BRTF's direction to heart to find compromise. I am deeply concerned that this decision will harden hearts and promote division in the SCRSG.

"As you may know, I have stuck to my post and to my commitment to the MLPA process through considerable distraction as my mother lay on her death bed. I did this, believing that she would have wanted me to do so, as she was a dedicated biologist that loved our California Coast. Now I am faced with the regret that all of my and my colleagues work was in vain, due to this last minute decision that threw out, on an apparent whim, the I-Team and the BRTF's former direction.

"I hope that you and the BRTF will answer my concerns and inform me why I should continue my efforts on behalf of the Marine Life Protection Act.

"With respect, I submit this as a request to explain what appears to be a breach in good faith by the 'powers that be' and to request why I should continue to expect fair and equal treatment by the Blue Ribbon Task Force and the I-Team.

"Respectfully yours, Captain Louie Zimm, Scripps Institution of Oceanography (retired)."
Zimm is not alone on this. Members of the regional stakeholders group I contacted question Wiseman's leadership and say they will never trust him again on any matters.

The entire MLPA process could be investigated by the state Senate if Sen. Dean Florez (D-Shafter) has his way, and we're still waiting for that to get started. At least two Fish and Game Commissioners, Dan Richards and Jim Kellogg, want Gov. Schwarzenegger to halt this process until the state gets well financially. Considering the fact the Governor is about to close state parks, sell places like the Del Mar Fairgrounds, cut state employee pay even more, shutting down this star-crossed process seems like it would be an easy decision. But that's how entrenched the preservationist-environmentalists are in our state government.

In the meantime, the Fair Political Practices Board continues its official investigation into charges of conflict of interest against Michael Sutton of the Fish and Game Commission.

Roman Porter, the executive director of the Fair Political Practices Commission, confirmed this week that the investigation of Sutton's ties continues. Sutton was sent a letter from the FPPC on May 19 informing him that he is being investigated for allegations that his ties to the Packard Foundation, which funds the MLPA process and the Monterey Aquarium where he's an officer, have influenced his votes on the Fish and Game Commission regarding marine protected areas.
Porter said there is no time limit on the investigation and he could not speculate how long the investigation will take.

Will fishing groups seek a court injunction against Sutton to prevent him from voting on the MLPA process until the FPPC investigation is complete? And if Sutton is found to have conflicts of interest and is fined, will his previous votes as a commissioner regarding the MLPA process and marine protected areas be ruled invalid and rolled back? What a mess that could turn out to be. I'm told lawyers for fishing groups are standing by on this.

Considering this latest crawfish move by Wiseman and the I-Team, the entire bunch needs to answer why it, as one stakeholder told me, moved the goal posts on the stakeholders after they thought they kicked a winning field goal and booted out the worst proposal of all, External Proposal C, from the MLPA process.

Those are the words stakeholders are using today about Wiseman and his I-team. They moved the goal posts. They're playing dirty pool. They changed the rules. They are not to be trusted.

Nice process. Nice I-Team leadership.