Welcome to our meeting where we will be discussing marine protected areas.
Before we commence with the proceedings, I'd like to acknowledge Mr. Peter Stoffer, who was the member of Parliament from Sackville—Eastern Shore. Mr. Stoffer was at a meeting at the outdoor caucus that I happened to attend last night.
It's great to see you here, Mr. Stoffer, with your lifelong interest in conservation and all things environmental.
We have today four witnesses. We have witnesses from the Canadian Sportfishing Industry Association, Phil Morlock and Angela Darraugh. From West Coast Environmental Law Association, we have Linda Nowlan. From the World Commission on Protected Areas, we have Mr. Stephen Woodley from the IUCN. As an individual, we have Dr. Sean Cox, associate professor and director of the school of resource and environmental management. We will take our witnesses in the order that I just read them out.
For our witnesses, you will each be allowed 10 minutes to speak, and I will do my best to enforce that time in the interests of fairness, so that everybody gets the same amount of time. After that, there will be a round of questioning from the members of Parliament on the committee. When you're around the two-minute mark, I'll stick two fingers up to let you all know that you have two minutes left. I will try to enforce that time fairly rigorously.
We will start off with Mr. Phil Morlock, who's chair of government affairs for the Canadian Sportfishing Industry Association.
Mr. Morlock, you have 10 minutes.
Thank you, Mr. Chairman. I appreciate the invitation on behalf of the recreational fishing industry. My professional background is as a biologist in criminal law. I'm here on behalf of the folks you see listed here in my presentation. They are the board of directors for the recreational fishing industry in this country.
It's a little difficult to explain all of this in 10 minutes, but I'll do my best. I'll go through my slides quickly, so please read along as we go.
We are the largest constituency for Fisheries and Oceans Canada, for that agency. If you ask eight million Canadians if they fish, the answer would be “yes”. Those are our customers, mainly middle-class Canadians, coast to coast, who like to go fishing and take their kids, families, and friends.
We're a significant economy in this country, as well. Federal stats say it's an annual $9-billion economy. We also influence a number of other economies that are partnered in this, if you will. They are listed here in my presentation.
We also have commonality between our retailers in the hunting, trapping, and target shooting area, and government policy and legislation. These are the fundamental basics upon which our industry thrives, and the related industries, as well. To put it pretty simply, without fish, people don't need much fishing tackle and people don't go fishing. The importance of a sound science-based policy is critical to the management and sustainability of our business.
We come from a pretty proud history across the North American continent, with over a century of successful examples and leadership from people from the fishing and hunting community. This even extends into the concept of parks and protected areas first advanced by our ancestors, if you will, in the fishing and hunting community. It has become today the most successful example in the world of fish and wildlife management: the North American model of conservation. Nowhere else on the planet has the successful populations of fish and wildlife that we enjoy in Canada and the United States.
That's changing, though, and it's been changing for some time. The stage is set for these changes to happen. You can see here in my presentation the threats we've been experiencing for going on 20 years now, and I'll explain why we see them as such.
Most importantly, I have here in my presentation the arbitrary national protection targets that, as far as we can tell, have no real basis in site-specific, independent science. This is what we have been confronting on the North American continent now for quite a period of time. When protection zoning is brought forward, we ask, “Protecting them from what? What's the scientific evidence? What's the hard evidence? Is recreational fishing a problem?”
Marine protected areas have a significant role in fishery management, but they're only one tool in the manager's tool box. That's changing, though. Presently, the change is one-size-fits-all. Successful fishery management has proven that many other prescriptions are successful—in fact, in some cases, even more successful than protected areas.
Dr. Larry McKinney at Texas A&M University managed fisheries for the State of Texas for 22 years. He is well respected across the scientific community in North America. I was discussing this with him a little while ago, and I asked him for a comment, which I've included in my presentation. I'll give you a second to read it.
There are over 300 marine protected areas in the Gulf of Mexico, all of which allow fishing.
In Australia, they've experimented with this for some time. There have been a couple of papers put out by some fairly well-known people in the science community that question the validity of the approach that's been taken. They ask if the prescription fits the ill. I only have them in English because they're proprietary and they're in a published document, so copyright prevents them from being translated. If anybody wants them, though, I have copies.
This is essentially how we see the situation from the recreational fishing industry. It's the North American model of science-based resource use that's under assault. It's been happening for quite a time.
It began on the east coast with the opposition to the seal hunt. It evolved from there with efforts against trapping, against hunting. The Ontario spring bear hunt campaign, some of the best management science on the planet with bear population, yet it was overturned and it has extended now into fishing. This is how these things are being promoted: the claims of dying oceans and no fish. In fact, we have some of the healthiest fish populations on the planet on this continent and in this country, and they're not here by accident. They're here by management based on science.
What do California and British Columbia have in common? This goes to the PNCIMA process, and I understand that this committee is pretty familiar with PNCIMA. This is California back in 2008, a healthy economy, lots of people fishing, 60,000 jobs, but when the process began for the Marine Life Protection Act there was no consideration for recreational fishing, and the state was broke. You all remember the crisis there. The environmental groups went directly to the government with money to influence the outcome, and it did. This is how it played out.
From our friends in the sister organization, the American Sportfishing Association, the money went to the Resources Legacy Fund Foundation, was managed, then went directly to the State of California process. This is how the American Sportfishing Association saw the example.
These are the people who supported it, the organizations. The only option considered was closures, no-take zones, permanent no fishing, no extractive use of any kind. That was the agenda.
This is an example, the central coast of California, and the impact was significant. Even though it looks on a map as though it's not that big an area, anybody who fishes knows that fish don't live everywhere. They are in certain prime habitat. It targeted prime habitat areas, over 40% of the best sport fishing areas in state waters out to the three-mile limit, and the impact on the economy was significant.
The boating industry and the vehicle industry had an even greater impact in a negative way. Gordon Robertson is one of the most respected people in the United States when it comes to fisheries issues, and I'll share this comment with you that he made about that process in California.
How is this relevant here? It's the same timeline. Fisheries and Oceans Canada brought the Marine Life Protection Act process to Canada. Our industry was not invited. Here it is again, a year later. You can remember the Resources Legacy Fund Foundation that managed the money in California. Here they are again, setting the template with Fisheries and Oceans for Canada.
We wrote to the minister on this and she wrote back and promised that we would be engaged. This was 2009. We're still waiting for that to happen, seven years later. The promises made to us were never kept.
Here's a press release from Fisheries and Oceans Canada talking about the money. Notice the common connection to the funding in California. This is the rest of the press release and is exactly like what happened in California, money going directly to British Columbia employees and the province. This information is all from the DFO website and this is the influence here. You can see some common names to the California process as well.
This is how the template works. The money goes into the initiative. In many cases there is purchased science, scientific opinions, which aren't the same as hard science in the field, of course, scientific data, and it influences the outcome. This is just one example of the money and how much money has been involved in this, basically from their own website.
There's a lot of money coming out of California, influencing the Canadian process. DFO designed the plan, and it has continued apace. Even though they backed away from the funding model, under the direction of the Prime Minister's Office, the plan has continued apace.
There's no involvement from our industry. We haven't been invited. Our participation has been declined. We've asked for copies of the memorandum of understanding. We were refused. There is a lot going on behind the scenes, and I think former prime minister Stephen Harper's comment here is appropriate and fits the situation very well.
Thank you, Mr. Chair. Good morning to you, and to the committee members. I'm pleased to be here today to talk about this critical issue.
We believe that amended legal provisions in the Oceans Act can help speed up the slow pace of ocean protection. Law is one of the solutions, and you have the power as legislators to recommend and make legal changes to the Oceans Act.
Progress in ocean protection lags far behind progress in park designation on land; however, where there's a will, there's a way. Political will is the first necessity, and your government has shown that it wants to play catch-up.
Other countries have made astonishing progress in a short time frame. The U.K., Scotland, Australia, California, all the countries in the European Union, and South Africa are examples. Many of these places with successful records on MPAs share a key feature. They have introduced bold new laws or policies that compel action. Canada can learn from their experience. A strong legal foundation is one of the enabling conditions of success.
MPAs do work, as you've heard from other witnesses. I won't go over the science, because I am not a scientist. I am a lawyer.
We also need to remember what we've lost. A former fisheries minister testified to Parliament during debate on the Oceans Act and recalled what John Cabot said when he reached the shores of Newfoundland in 1497. He found the sea swarming with fish that could be taken not only with a net, but with baskets let down with a stone. There are many similar stories in our history. There's no doubt the oceans are no longer as full of fish as when John Cabot came to our shores.
I'd like to make three key points today from my expertise in law. First, there is a great opportunity now to re-establish Canada as a leader in ocean law. Second, your report can help the government with one of its five points in its action plan by recommending legal amendments for faster and more effective MPAs, and third, it's time for Canada to meet its legal obligations.
First, on re-establishing Canada as a leader in oceans law, Canada took a lead role in drafting the UN Convention on the Law of the Sea. Canada passed the Arctic Waters Pollution Prevention Act in 1970 to ensure special protection for that area, and former prime minister Brian Mulroney was the first world leader to sign the biodiversity convention in 1992, which is the foundation for our legal obligation to create protected areas on land and at sea.
At the time the Oceans Act was passed in the late 1990s, it was groundbreaking, comprehensive legislation dealing with oceans in a holistic manner, but that leadership role has been lost due to its slow implementation. We've prepared a chart comparing countries similar to Canada and their progress in designating MPAs. I apologize that I have it only in English, but I do have copies available.
The timeline shows different rates of progress. The results are quite startling. In 20 years Canada has protected less than 1% of the ocean. That is less than 1%, in 20 years, under the Oceans Act. Contrast this to progress in the U.K. In the seven years since the Marine and Coastal Access Act was passed in 2009, MPAs have grown from 6% to over 20% of U.K. waters, and they are not done. In the next year the government will legally designate another group of MPAs to its network. In less than half the time we've been at it, the U.K. has far outstripped Canada with progress. We are at 1%. They are 20%. They are also aiming higher. Their biodiversity strategy calls for 25% of English waters to be protected. Just last week their Environmental Audit Committee released a report, “Marine Protected Areas Revisited”. I urge you to look at that.
Second, the government is considering how to reach the fifth point in 's oceans action plan, which is to establish marine protected areas faster. The government pledged to “Examine how the Oceans Act can be updated to facilitate the designation process for MPAs, without sacrificing science, or the public’s opportunity to provide input.” This committee can assist with that work and its recommendations, and we encourage you to recommend amendments to the Oceans Act. The recent report from the environment committee has some excellent recommendations that this committee could repeat for emphasis.
In our view, the government can short-circuit the prolonged process, which on average takes seven to 10 years to create an individual MPA under the Oceans Act, and provide guidance by putting minimum protection standards into the act.
The science is clear on the need for these standards. The law should incorporate the science and be equally clear. We have three recommendations on how to incorporate these standards for more certainty for ocean users.
First, set general prohibitions against damaging activities instead of negotiating on a case-by-case basis each time.
Second, require assignment of an IUCN category to each MPA, as the IUCN guidance documents suggest. I know you heard from Dr. Dan Laffoley of the IUCN, and we have Stephen Woodley here who can also talk about the IUCN. This is the global standard, and IUCN categories, when established for each MPA, are a very good management tool.
Third, you could recommend that ecological integrity be the primary goal for the marine protected areas, as it is for land protected areas such as under the Canada National Parks Act. The law could also establish timelines. Setting out milestones and key deliverables in the law has proved successful in the European Union.
Finally, it's time to meet our legal obligations. These come from a number of sources, including treaties like the Convention on Biological Diversity from 1992, the Convention on the Law of the Sea, and targets like the Aichi targets you've heard about, and also the UN sustainable development goals.
The numerical target of 10% is a decade old. In 2006, the eighth conference of the parties to the biodiversity convention adopted the 10% protected area target. Another chart that we prepared shows the evolution of these legal provisions over the years. Canada is legally obligated to protect marine areas.
In conclusion, now is the time for Canada to regain its leadership in ocean law and ocean protection. Now is the time to make good on the promise of the 20-year-old act by strengthening it and making it more robust and effective. Now is the time for effective marine protected areas for our salmon and cod nurseries, our whale-breeding grounds, and our 1,000-year-old glass sponge reefs, among other ocean wonders.
Now is the time to take steps to ensure all three of our oceans are healthy and remain that way for future generations. As legislators, you can act. The has given you the mandate to ramp up ocean protection. Where there's a will, there's a way.
Thank you, Mr. Chairman, and thank you for inviting me here today.
I am a scientist and I work for the World Commission on Protected Areas of the International Union for Conservation of Nature, where I'm the vice-chair for science. Over the last four years I've been chairing an organization or a task force specifically looking at whether protected areas are effective, and if so, why? Why and when are they protected? The literature on protected areas had been, frankly, pretty messy. We tried to put some order to this and put together some global analysis based solely on data upon when and if these places are effective. It's in that context that I want to speak to you today.
I know my colleague Dan Laffoley spoke to you already. He has explained to you what the IUCN is, so I won't go over that other than to say it's a unique organization in that it has a government house and an NGO house. I don't know of an equivalent organization today. Canada is a very strong and active member of the IUCN.
In defining what a protected area is, the IUCN actually set the global definition. It was agreed to by Canada. It's equivalent to the definition used by the Convention on Biological Diversity, and it's the same on land and on sea. I don't think I need to repeat it for an audience such as this.
It's worth going over briefly the benefits of having a marine protected area, because I think that's germane to the discussion today. It is not to tie up areas that we can't have access to; it's really to allow that the management we do in the larger oceans be done correctly. MPAs provide benchmarks. How else will we know the impact of fishing and other activities if we don't have a benchmark? It's science 101. Establishing these areas as benchmarks is fundamental.
In terms of looking at protected areas as a tool, I've just done a global review on this for the Global Environment Facility. We looked at all the tools we use to protect nature: harvest management, protected areas, management of species at risk, and so on. If you look at all the literature on these things, protected areas come out as the most effective tool in terms of response ratio or bang for your buck. They are an essential part of fisheries management. In Canada, we have not taken advantage of that tool, as my colleague just pointed out. I don't need to reiterate it.
They can also raise the benefits for marine tourism, benefiting local communities globally. This has been shown all over the world. A recent study in Scotland showed, despite economic doom predictions to the contrary, that setting up MPAs actually benefited local communities economically.
There are a whole range of benefits for MPAs, the last ones being really the direct benefits of conservation in ecosystems, because there are some areas, either representative areas, areas for species at risk, or key biodiversity areas such as spawning sites, that are worthy of protection in the larger context.
Let's turn to the question of whether MPAs are effective in conserving nature. There's quite a growing amount of literature on this now. The task force I chaired has been able to contribute significantly to this literature. I'll start with a global synthesis that was done by Lester, and others, and here are the conclusions.
Overall, MPAs demonstrate statistically positive impacts on fish biomass, numerical density, species richness, and size of organisms within their boundaries. Those benefits, depending on which study you look at, are very significant. You can have 10 times more fish inside a protected area than you do outside.
Those benefits are also relevant to our ecosystems, the Canadian ecosystems. Much of the research was done in the tropics and sub-tropics, but this global review showed that the temperate ecosystems have the same kind of response. That has been a question in literature. Surprisingly to me, even small reserves can show positive impacts. Large reserves are better—the literature is clear on that—but even small reserves can show positive impacts.
There's variation all over the place. We tried to understand why there is so much variation in the literature.
Graham Edgar and his colleagues from Australia did another global study and they looked at what was driving protected area effectiveness. They concluded, a bit shockingly, that globally, many MPAs can't be ecologically distinguished from fished areas. There's simply no difference because they're MPAs in name only. We've had trouble translating the protected area model into the ocean because most of them are fished. Therefore, there's really no delta or difference between fished and unfished and this applies to Canada. Even if you look at some of our larger marine protected areas, like the Gwaii Haanas National Marine Conservation Area Reserve and Haida Heritage Site, since it was declared a protected area, there's been no change in fisheries management. It's the same. We haven't taken advantage of that because of the way the act is constructed and the way that it's been managed.
Edgar, et al., found that some areas are extremely effective. They boiled it down to five key features for what's driving effectiveness. There's no-take. There's good enforcement, and globally enforcement is really poor. It probably wouldn't be the case in Canada. Also older ones do better, larger ones do better, and ones that are isolated by some biophysical feature also do better. When you have all of these five features working together, you get nine times more fish biomass on average and 39 times more large predators, like sharks, in these areas because you don't need much fishing to take large predators out of the system.
Overall, fish biomass on reefs is reduced two-thirds compared with protected areas. We published a paper in the journal Nature just last month. I'll refer to it as the Gill, et al., paper and I'll provide that to the clerk. That was part of the work of the IUCN task force. We found that a sobering 79% of the global sample of protected areas weren't meeting thresholds for basic management. They didn't have enough staff in place. They didn't have funding. They didn't have monitoring in place, etc. Staffing and funding gaps were the biggest predictors of conservation outcomes. Even despite these shortcomings, three-quarters of these protected areas were showing positive biological impacts. If you compare with well-managed areas, we get three times the value, so you get three times the value in terms of fish biomass for having a well-managed marine protected area.
I could go on about the benefits and I'm happy to, but I'll provide a number of key papers to the clerk should you be interested. I just have three quick conclusions.
There's ample evidence that marine protected areas work. The evidence is quite strong and interestingly enough, and it's stronger in marine areas than on land.
Protected areas need to be put in the right places for conservation, so that they actually do protect nature, and not simply put it in places where they avoid a conflict with fishing.
This committee is justifiably focused on Aichi target 11, or Canada target one. I ask you to also consider Aichi target six, which is upgrading our fisheries management, because we can't lump everything into Aichi target 11 in terms of the things that should be done in the oceans. We need a whole oceans approach.
Finally, I agree with the notion that we need some legislative review. If I look at the National Marine Conservation Areas Act, it does not have meaningful ecological end points, like ecological integrity, and I think it could benefit from strengthening, as we move this agenda forward.
Thank you very much.
I just want to give you a little bit of additional background on myself. I'm also the co-founder and chief technical officer for Landmark Fisheries Research, which is a small consulting firm. We do research that supports the fisheries community, including fishing associations, Fisheries and Oceans Canada, as well as some environmental organizations. Most of our projects involve fishery stock assessment, harvest strategy analysis, survey design, as well as some ecosystem-based management strategy development.
I'm also the chair of the scientific review board for the International Pacific Halibut Commission, and I'm a member of the joint technical committee for the Pacific hake treaty.
My background lies mainly in fisheries science, stock assessment, survey design, harvest strategy evaluation, and more collaborative ecosystem-based fisheries management. I've been involved in several assessments on both the east and west coasts of Canada, in Chile, and in South Africa. I have a bit of experience, and most of it is in fisheries management directly.
I have a few points about MPAs. I'm not an expert in MPAs, but I am a fisheries scientist and can understand the role of MPAs. I do happen to work on one, which is the Bowie Seamount Marine Protected Area on the west coast. I am also involved in some of the rockfish conservation areas on the west coast.
Most of my points are not going to be very supportive of MPAs in general for fisheries management. As Stephen just pointed out, there may be benefits to closing an area to the local sedentary fish populations within that closed area, but the actual benefits to fisheries are quite minimal.
I'll just go through these points.
First, protecting land resources is very different than protecting resources in the ocean. The ocean is a transport medium. It moves nutrients, water masses, and organisms over thousands of kilometres, and it may not move them over the same thousands of kilometres from year to year. Putting a static MPA in place in the ocean will protect a particular species or group of species in a particular area at a particular time.
Looking at some of the previous testimony, there was a claim that there was overwhelming scientific proof that MPAs are beneficial and widely successful. I think that was misrepresentation of the actual science. Stephen just cited some of the studies that find that they're not broadly successful.
In fact, I was going to mention these five criteria. For an MPA to be successful, you need all five. You need 100% protection. You need very strict enforcement. You need long duration before you can detect any changes. They need to be at least 100 square kilometres in size. They need to be highly isolated. The last one—being highly isolated—is really hard to meet. In fact, only four of the 87 MPAs around the world in that study could actually be considered successful.
Just enforcing MPAs would be hugely expensive. Again, if you're looking at it from a fisheries management point of view, it's far more cost effective to do other things that don't cost that much.
A point I'm going to make later about that enforcement issue is that one of the things MPAs do is promote a lot of illegal fishing. If you look at our abalone fisheries on the west coast, they're subject to rampant illegal fishing.
Our RCAs, the little rockfish conservation areas along the coast are almost all fished. The only ones who don't fish in there are the commercial fishing vessels, which have vessel monitoring systems on them that can actually detect if they go in these areas. All the recreational boats, first nations, and anyone who wants to go out and sell fish on the black market can go in those areas. As you know, these are really remote places where it's not difficult to go in and fish illegally.
MPAs aren't likely to be effective scientific tools, either. They're not easily replicated. When you put in an MPA, it's subject to a high degree of what we call “location and time” effects. You can't just create a nice experiment where you have three of the same type of MPA in one place and then three control areas in another place. You just can't do that. They're wide open to outside perturbations, environmental changes that are not within our control.
The big issue is that the sampling of ecosystems, at least over a large area like 100 square kilometres, has very low statistical power. That means you have a low probability of actually detecting any kinds of changes, even if they actually exist, unless you spend a whole lot of money. Sampling marine systems is very expensive, it's time-consuming, it's technologically demanding, and it's always biased. On land you can go out and observe things or use satellite imagery. You can't do that in the ocean. You have to put some sort of sampling gear down to collect organisms, and that's always biased.
The MPA benefits to fisheries, as I was mentioning, are marginal. There's some evidence for this. Implementing Canada's sustainable fisheries framework is probably a more effective activity than using MPAs, broadly. Issues like discarding and misreporting are not, at least on the west coast of Canada, major issues, at least in the commercial fisheries. Those are either monitored directly by human observers on 100% of groundfish vessels or video-audited logbooks are used. The monitoring system on the west coast is the standard. It's the best monitoring system in the world. There are also strong limits on discarding in our fisheries on the west coast as well.
I made the point earlier about illegal fishing. The prices that are out there for sablefish and halibut are huge. In fact just this weekend I was talking to somebody who found himself fishing in a rockfish conservation area by accident this past summer. He couldn't believe how fast they were catching halibut. That was because there are no commercial fisherman in there, and somebody can get in there and fish illegally quite easily.
I just want to make a couple of points about when MPAs could be effective.
I think MPAs are needed to protect non-commercial benthic invertebrate species such as corals and sponges. These kinds of things form fish habitat. Nobody wants to destroy them. They're generally sedentary. They don't move very much. They tend to have high larval retention in the areas where they occur, and they have this isolation feature. They're mappable. They're not moving. The data you collect today will probably be relevant 20 years from now. We can build maps of where these things probably occur and actually work with them.
In fact, a lot of the fishing industry on the west coast, the groundfish industries that tend to affect bottom habitat, and all of those organizations support protecting sensitive benthic habitat. Just throughout the MPA that I work on, the Bowie Seamount, Wild Canadian Sablefish has spent over a quarter of a million dollars studying corals and sponges in that marine protected area. They developed their own custom deepwater cameras and motion-sensing systems on their gear. They're doing everything they can to try to minimize impacts on those resources.
My final point is one that was raised earlier, about just the arbitrariness of choosing 10% or 20% MPA coverage of the ocean. I think this needs to be reversed a bit. I mean, 10% or 20% is not 10% or 20% of ecosystems or of species. I think the point is to try to establish some sort of practical and feasible set of goals that can be put in place for particular species in particular ecosystems and start from there. It's much easier to sell this kind of practical and feasible set of goals than it is an arbitrary 10% or 20% approach.
There's a general rule in fisheries stock assessment, population dynamics, and so on that you cannot know the optimal size of a stock until you overfish it. Letting a stock grow to its largest size tells you nothing about the optimal productivity of that stock. That's a mathematical kind of thing.
Over the past couple of years, I've been working on two of the cod stocks, the northern cod in 2J3KL and the southern gulf. The southern gulf stock is about to be extirpated. No marine protected area is going to help it because it probably is the seals. The stock is so low that even a small amount of predation by seals is enough. That seal population has gone from about 9,000 in the 1970s to in the hundreds of thousands now. It's a completely different ecosystem in there.
The northern cod, it turns out.... A year ago DFO put together a competing stock assessment type of meeting where two people, Noel Cadigan and I, both developed independent stock assessments for northern cod. One of the things that came up—DFO scientists at the time thought it was going on but nobody really believed it—was that there was an increase in natural mortality just prior to the collapse. Both of these models are showing this. It's the same thing that we see in the southern gulf, high natural mortality. It's a different type. It's a high, persistent, natural mortality in the southern gulf, but it was some sort of mortality event in northern cod.
Then there was another event in the late 1990s soon after the moratorium. There was another one of these relatively high natural mortality events. That could have been one of the things that prevented recovery following the closure.
The issue here is that we have a really hard time predicting anything about nature. That's one of the arguments in favour of MPAs. If you can't predict anything, then just close it, which is fine if that's what you want to do. Some of the predictions of what MPAs are going to do and how they're going to benefit, I think, are not quite as robust as they could be.