Benefits and Disbenefits of Co-locating Windfarms and Marine Conservation Zones

ISSUES DOCUMENT FOR STAKEHOLDER REVIEW
21st October 2010

1 ICHTHYS MARINE, 21/10/10. ISSUES DOCUMENT- SUBJECT TO REVIEW

Introduction
In June 2010, Ichthys Marine published a report for COWRIE that considered the options and opportunities to mitigate any impacts that may occur to the fishing industry as a result of the construction of offshore windfarms (Blyth-Skyrme 2010). A menu of possible mitigation options was created, which could be used by fishermen, developers and other interested parties in discussions related to current and future developments. One of the options identified to mitigate impacts was to co-locate windfarms with marine conservation zones (MCZs). This was because MCZ conservation objectives may require that some or all fishing activities are stopped inside these sites, while some or all fishing activities may also be excluded from windfarms for safety or infrastructure protection reasons. Hence co-locating rather than separately siting windfarms and MCZs might reduce their combined impact on the fishing industry. After completing the 2010 report, further work was proposed to consider the implications and enthusiasm for co-locating windfarms with MCZs in more depth. This would include through consulting with the main interest groups, including windfarm developers, the fishing industry, nature conservation organisations, the regional MCZ projects, and fisheries managers. It is intended that the potential benefits and disbenefits of co-location are identified through this work, in order to inform the windfarm development and MCZ designation processes. A key part of this work is to provide stakeholders with an opportunity to comment on a draft list of benefits and disbenefits that has been created following a review of existing literature and through initial discussions with stakeholders. This draft list is provided on the following pages. The objective is to gather stakeholder comments on:      Is the list of benefits and disbenefits complete, should more be added, or should some be discounted as not being relevant? How important are the different benefits or disbenefits? Are any of the benefits so great that co-location must be applied? Are any of the disbenefits so great that co-location should not be considered? Other issues as identified by stakeholders.

A feedback form is provided for these purposes at the end of this document.

Offshore windfarms and commercial fishing
For the purposes of this work, towed gears are defined as demersal fishing gears that must be actively moved along the seabed; these include otter trawls, beam trawls, scallop dredges, mussel and oyster dredges, and Scottish seines. In turn, static gears are defined as those that are set and left in place, these include pots, anchored gill or tangle nets, and long-lines. Publicly available environmental impact assessments or other documents from a sample of 16 UK offshore windfarms were examined. These indicated that no attempt will be made at eight (50%) of the sites to restrict fishing activities beyond the statutory 50 m exclusion zone that will be applied to all UK offshore turbines. At another four (25%) of the sites, exclusions will reportedly be extended to 500 m for towed gears, so that only static gears will be permitted. Documents for the last four (25%) of the sites were not clear about permitted fishing activities. Even where fishing is permitted, it is unclear if fishermen will be prepared to work inside windfarms. There is no indication that insurance premiums would be higher for vessels to fish inside (BlythSkyrme 2010), but there are concerns in the industry that manoeuvring vessels and gear around and between turbines may be difficult or dangerous, particularly in inclement weather or strong tides (Dr. Stephen Lockwood, MCZ Coalition, pers. comm.). There are anecdotal reports of both towed and static fishing gears being used at some sites, but data or studies were not available to this study.

2 ICHTHYS MARINE, 21/10/10. ISSUES DOCUMENT- SUBJECT TO REVIEW

MCZs and commercial fishing
For MCZs, as for windfarms, towed fishing gears are likely to be of greatest interest because of the higher risk that they pose to maintaining or achieving favourable (ecological) condition of the sites. Strict criteria are being applied to reference area MCZs, which are defined as sites where "all extraction, deposition or human-derived disturbance is removed or prevented” (NE & JNCC 2010). Although there is no specific management advice yet available, this implies that fishing of any type will not be permitted inside. However, such reference area MCZs should make up the minority of MCZs, as only one area example (at least) of each broad habitat type and feature of conservation interest needs to be protected within each regional project. In contrast, the majority of the MCZs within the network will have protection levels "which ensure the favourable condition of the MCZ features and no further degradation" (NE & JNCC 2010). It is thought that Good Environmental Status will act as the minimum acceptable level for MCZ conservation objectives. Because management advice is not available, the implications for fishing activities in the majority of the MCZ network are not clear. However, it seems appropriate that habitat types, gear types, conservation objectives, and existing levels of activity will be taken into account when determining what management regime will be imposed, and that some level of static or even towed gear fishing activity should be compatible with many sites.

Guidance on co-locating windfarms and MCZs
Legislation and a variety of policy documents exist which provide guidance on the approach to socioeconomic issues being taken in the MCZ network designation process. These do not necessarily provide a significant level of detail on co-location, but do indicate that social and economic factors will be important; the relevant documents include: a) The Marine and Coastal Access Act: (UKGovernment 2009). "Clause 117 (7). In considering whether it is desirable to designate an area as an MCZ, the appropriate authority may have regard to any economic or social consequences of doing so ." b) Draft guidance on selection and designation of MCZs (note 1) (Defra 2009): "Section 5.12 In addition to the ecological factors set out above, we propose that the following practical considerations are applied in selecting MCZs and drawing their boundaries...  The area will provide conservation benefits through excluding activities for reasons of safety (e.g. exclusion zones around offshore wind turbines) or danger areas . c) Offshore energy strategic environmental assessment (DECC 2009). " Where the objectives of the conservation sites and renewable energy development are coincident, preference should be given to locating wind farms in such areas to reduce the potential spatial conflict with other users.” d) 02/09/2010 Scottish Ministerial Statement on the creation of a network of MPAs (ScottishGovernment 2010): "We believe that we should encourage the co‐existence of MPAs and social and economic activities where they are mutually compatible as this exemplifies the key spirit of sustainable development ." e) MCZ project; additional guidance for regional MCZ projects (NE & JNCC 2010): "There are significant socio-economic benefits in integrating MCZs with existing activities; wherever possible regional stakeholder groups are encouraged to identify these synergies to provide for 'win win' situations. f) MPAs Science Advisory Panel response to Finding Sanctuary; assessment of performance against principles (MPASAP 2010): "The issue of whether such co-location was desirable/feasible was discussed by the SAP and, although there were advantages and disadvantages, such co-location was considered acceptable and potentially beneficial from a scientific point-of-view."

3 ICHTHYS MARINE, 21/10/10. ISSUES DOCUMENT- SUBJECT TO REVIEW

Co-location: potential benefits
The following is a list of potential and perceived benefits of co-location that might accrue to individual sectors or groups of sectors as stakeholders in windfarms and/or MCZs. The intention is not to singleout a particular stakeholder group, but to review any and all potential benefits.

1) May minimise the combined social and economic impacts of windfarm developments and MCZs
The primary reason for co-location would be to minimise the socio-economic impacts incurred by the fishing industry from establishing separate windfarms and MCZs. Notes from the regional MCZ project stakeholder groups include: Finding Sanctuary: "There was a debate whether the group should be considering co-location as possible or not possible in case the easy option (no co-location) is chosen which would take more ground away from commercial fishing." (FSIWG 2010); Balanced Seas: "It was agreed that where wind farms can be co-located with MCZs (i.e. the ecological features are adequately protected), this will be highly beneficial to all concerned, and the project should make sure such opportunities are sought." (BSSG 2010); The potential socio-economic benefits for the fishing industry from co-location are greatest when active fisheries would be excluded from a separate windfarm and MCZ, but then these sites are colocated instead. In that case, fishermen would lose just one fishing ground rather than two. In some cases, though, benefits from co-location may accrue to only particular fishing sectors. This could be the case where towed gears were excluded from a co-located windfarm and MCZ, but static gears were permitted. Static gear fishermen who were prepared to fish inside the site would potentially gain through being protected from any gear conflict issues.

2) May support windfarm developers' efforts to work with local fishing communities
Engaging local stakeholders in order to generate productive and useful input to developments can be a difficult task, although the level of importance to a windfarm developer of engaging the fishing community is likely to be at least somewhat dependent on the level of fishing activity at the site. It is relevant to note that the zone appraisal and planning (ZAP) process, as devised by the Crown Estate and as apparently adopted by the Infrastructure Planning Commission before being abolished, focused strongly on the benefits of stakeholder participation in the strategic planning process. Although the ZAP process is non-statutory, it is intended to improve the ability of developers to understand, mitigate and eliminate conflicts and risks (TheCrownEstate 2010). Even if co-location does not automatically provide benefits to all fishermen, working through the options for co-location in an effort to minimise social and economic impacts may provide a useful focus for discussions between the fishing industry and developers, and lead to better working relationships.

3) May be consistent with windfarm developers' efforts to promote environmental sustainability
Windfarm developments are commercial enterprises with a the focus on environmental sustainability. For example, the website for the Sheringham Shoal offshore windfarm states "The world needs more energy, and in future ever more of its energy supply will need to be obtained from renewable resources such as hydropower, waves and wind.". It may be that marketing and public relations opportunities exist through developers being able to advertise their site as being co-located with an MCZ. For example, the MPA Science Advisory Panel commented: "The guiding principle in considering existing zoning should be that if the area contains 4 ICHTHYS MARINE, 21/10/10. ISSUES DOCUMENT- SUBJECT TO REVIEW

ecologically important habitats or species, then it should be considered for the establishment of a MCZ. Given the pressure on the marine environment, the aim should be to collocate compatible activities whenever possible." (MPASAP 2010). If, through co-location, a windfarm could be advertised as being compatible with ecologically important (marine) habitats or species, this could be used to provide a powerful message regarding the wider environmental sustainability of the development.

4) Restrictions on fishing activities within windfarms may support MCZ objectives
Reference area MCZs will comprise areas where "all extraction, deposition or human-derived disturbance is removed or prevented” (NE & JNCC 2010). As such, it is unlikely that any fishing activities will be permitted in these sites. In contrast, as long as conservation objectives can be achieved or maintained, it appears likely that some fishing activity will be allowed to continue in the other sites in the MCZ networks. However, because no fishing activity is entirely benign, the exclusion of fishing activities from within co-located sites may support achieving and maintaining favourable condition of the MCZs. The idea that benefits may be derived from excluding activities from windfarms was noted by the MPAs Science Advisory Panel: "Wind farms, for example, may be suitable for MCZs (although not for Reference Zones). They are good in the sense of excluding some disruptive human activities." (MPASAP 2010). Additionally, work on scallops has shown some potential for even relatively small closed areas to act as broodstock reserves to the benefit of adjacent fisheries (Kaiser et al. 2007). This was recognised by stakeholders in the Irish Sea Marine Conservation Zones project commented: "Should explore with scallop industry whether there are opportunities to co-locate MCZs with possible closed areas for scallop fishing, as conservation/enhancement measure" (ISMCZ 2010). Although this would not necessarily be an MCZ conservation objective, and advocating an MCZ or co-located site on the basis of fisheries benefits would probably be inadvisable, supporting scallop stocks to the benefit of the commercial fishery could be a useful by-product of protection.

5) Windfarms may support MCZ management through marking the locations of MCZs
A stated objective of the Marine and Coastal Access Act 2009 is to "recover and protect the richness of our marine environment and wildlife through the development of a strong, ecologically coherent and well managed network of marine protected areas, that is well understood and supported by all sea users, by 2012" (Defra 2009). Maintaining effective management control over activities undertaken within and around MCZs will be key to ensuring that network delivers environmental benefits. Co-location could offer benefits to managers through clearly marking the location and boundaries of the MCZs. Relevant information could even be displayed/painted on the turbine bases. In this context, the Balanced Seas Regional Stakeholder Group noted: "For both good enforcement and self-policing, the MCZs will need to be clearly identified and marked on charts so that people know where they are" (BSRSG 2010). Further, they said: "Education is going to be really important, especially to get the message across to individual users and unregulated sectors, particularly those in small vessels without GPS or tracking devices e.g. personal water craft, regarding the boundaries of MCZs." (BSRSG 2010) Monitoring fishing and other activities, and enforcing MCZ legislation more generally, is likely to be very challenging, if only because of the difficulties and costs associated with patrolling and monitoring large areas of sea. The regular monitoring and maintenance activity that is undertaken around windfarms as part of a developers commercial operations may act to deter any deliberate efforts to flout MCZ rules. Although there is no suggestion that windfarm developers should take on any enforcement responsibilities, simply providing information to managers and enforcement agencies on any prohibited activities could be useful.

5 ICHTHYS MARINE, 21/10/10. ISSUES DOCUMENT- SUBJECT TO REVIEW

Co-location: potential disbenefits
The following is a list of potential and perceived disbenefits of co-location that might accrue to individual sectors or groups of sectors as stakeholders in windfarms and/or MCZs. Again, the intention is not to single-out a particular stakeholder group, but to review all potential disbenefits.

1) Concern that developers may have additional responsibilities and costs with colocation
Windfarm developers are businesses that will seek to reasonably minimise any costs associated with their sites. Therefore, they may be unwilling to commit to co-location with MCZs without an assurance that the difficulty and cost of completing the consents process would not be increased. These concerns were raised at Finding Sanctuary: "The renewables industry is hardening its view against co-location of wind farms and MCZs since it could damage the consents process and lead to extra costs. They are not getting more definitive compatibility guidance..." (FSOWG 2010). In terms of additional costs associated with operational monitoring, the Marine and Coastal Access Act states: "Clause 124 (3). For the purposes of complying with its duty under this section, the appropriate authority for any area may direct the appropriate statutory conservation body for that area to carry out such monitoring of MCZs in that area as is specified in the direction." (UKGovernment 2009). The Act defines the 'appropriate authority' with regard to an area in Wales and Scotland as the respective Ministers, and in other cases as the Secretary of State. As such, it is clear that it would not be windfarm developers who would be required to shoulder the costs of monitoring MCZs. Although monitoring costs may not be an issue, there does appears to be a lack of clarity on development costs. A Finding Sanctuary group noted: "Even with a Government policy decision that co-location was ok, there would still be costs borne by the industry. These costs include not only marginal increases to construction/operating costs but also the perceived risk to investment and obtaining planning consent, both of which may limit the ability of developers to access the necessary investment finance to take projects forward." (FSIWG 2010). They also said: "Multi-million pound sites could be made unviable/unattractive to investors if designated with management measures that aren't compatible with renewable use. Particularly for wind farm sites, the renewables sector would like the IWG to look elsewhere to reduce the risk for the developing sites." (FSIWG 2010).

2) May limit access to fishing grounds inside windfarms which could otherwise be targeted
If a windfarm was constructed on a favoured fishing ground, and if fishermen were willing and able to fish inside the windfarm, then a co-located MCZ could result in that fishing activity being prohibited for conservation reasons. In such circumstances, fishermen could be socio-economically impacted to a greater extent by co-location through being displaced away from profitable grounds onto less productive areas, than if a separate MCZ and windfarm was established. Similar negative social and economic impacts on fishermen might occur if co-location displaced fishing activity onto similar grounds that were further away from port, requiring fishermen to spend more time and money in transit. Concerns over longer transit times between fishing grounds and port in bad weather may also reduce the number of days that fishermen would be able to fish, further reducing profitability.

3) Concern that turbines and turbine scour may compromise MCZ conservation objectives
An important and potentially controversial question concerning co-location is whether the physical presence of the turbines, together with any associated scouring, would prevent the site from achieving or maintaining favourable condition. The use of large quantities of scour protection material could further increase the potential for a site to be considered sufficiently 'non-natural' or permanently modified that it would fail to meet conservation objectives (NE & JNCC 2010). 6 ICHTHYS MARINE, 21/10/10. ISSUES DOCUMENT- SUBJECT TO REVIEW

Some guidance on the ecological acceptability of co-location was provided by the MPA Science Advisory Panel. It stated: "The issue of whether such co-location was desirable/feasible was discussed by the SAP and, although there were advantages and disadvantages, such co-location was considered acceptable and potentially beneficial from a scientific point-of-view." (MPASAP 2010).

4) Concern that cabling and EMF effects may compromise MCZ conservation objectives
Cables and cabling are fundamental aspects of offshore windfarms. The majority of any direct impacts from cables occur initially during burial, and it is only if the cables become exposed or malfunction and have to be repaired that any further physical damage is likely to occur. The effects of electro-magnetic fields (EMF) on marine animals such as the elasmobranches are relatively less well understood, but existing work suggests that this is unlikely to be a particularly significant issue. The Finding Sanctuary Inshore Working Group discussed the issues of cables and MCZs. A report concluded: "Two key assumptions underpinned the discussions and decisions made by the group: ... that that cables (renewables/telecoms) are compatible with MCZs" (FSIWG 2010) The MPA Science Advisory Panel's comments were also generally supportive of co-locating windfarms and MCZs, whilst noting the uncertainty that appears to surround the potential impact of EMF. The SAP noted "The issue of whether such co-location was desirable/feasible was discussed by the SAP and, although there were advantages and disadvantages, such co-location was considered acceptable and potentially beneficial from a scientific point-of-view." and "There is some evidence for negative impacts of wind farms on migrating birds, and some claims that subtidal cables can influence the electrosensing ability of elasmobranchs." (MPASAP 2010)

5) May require a greater compromise on where MCZs are located than is deemed appropriate
The Marine and Coastal Access Act 2009 states "Where there is a choice of alternative areas which are equally suitable on ecological grounds, socio-economic factors could be more significant in deciding which areas may be designated as an MCZ." (UKGovernment 2009). Essentially, socioeconomic factors may be a deciding factor, but they only become significant when a choice needs to be made between two sites of equal ecological value. The Ecological Network Guidance provides the detailed basis for what constitutes an ecological coherent network of MPAs, but it also confirms that sites must be selected for designation on the basis of their ecological value first and foremost. Seeking opportunities for co-location may result in the regional MCZ projects recommending ecologically sub-standard sites for designation. This has been noted by the MPA Science Advisory Panel, that stated: "All of the Regional Projects have so far taken an approach of mapping fishing effort and then designing MCZs around areas of high fisheries use or value. The stated aim is to minimise socio-economic impacts on fishermen. However, such an approach carries several risks: (1) that sites will be chosen for MCZs that are currently second rate from an ecological perspective; (2) that avoidance of such areas could undermine connectivity of MCZs; or (3) other stakeholders may feel that unfair advantages are being given to fisheries in the planning process ." (MPASAP 2010). It's possible that the quality of data on seabed habitats may be insufficiently high in some cases for detailed comparisons and analyses of ecological value to be undertaken. If that is the case, it may be more feasible to make a decision on site selection on the basis of socio-economic data.

6) Concern that MCZ designation may eliminate any fisheries reparation associated with windfarms
As was noted in the 2010 Ichthys Marine report for COWRIE, mitigation of impacts to 'keep fishermen fishing' rather than compensation to vacate a fishing ground was preferred by all the stakeholders who attended that project's expert advisory group workshops (Blyth-Skyrme 2010). Essentially, the advisory group agreed that compensation did not provide a long term option for fishermen to keep

7 ICHTHYS MARINE, 21/10/10. ISSUES DOCUMENT- SUBJECT TO REVIEW

fishing, and potentially provided less support for dependent communities and associated businesses than keeping fishing. There are apparently concerns, though, that if compensation is sought by fishermen to leave a site, no reparation will be forthcoming if that site was to be co-located. The thinking appears to be that the fishermen would have lost access to the site in any case because of its co-located designation. A Finding Sanctuary group commented: "The fishing representatives were concerned that if an MCZ is co-located within a wind farm area, then it could mean that developers would not be liable to pay compensation and they were keen to point out how valuable the North Devon area is to their industry and to reinforce that these fishermen are not able to diversify." (FSOWG 2010)

References
Blyth-Skyrme, R.E. (2010). Options and opportunities for marine fisheries mitigation associated with windfarms. Final report for Collaborative Offshore Wind Research Into the Environment contract FISHMITIG09. . London, COWRIE Ltd.: 125. BSRSG (2010). Balanced Seas regional stakeholder group meeting 2 report. http://balancedseas.org/gallery/download/333.pdf, Balanced Seas: 32. BSRSG (2010). Balanced Seas, Regional Stakeholder Group meeting 4, meeting report, 9th September 2010. http://www.balancedseas.org/gallery/download/513.pdf: 31. BSSG (2010). Balanced Seas Solent/Isle of Wight/Hampshire Stakeholder Group meeting 2, meeting report, 15th July 2010 http://www.balancedseas.org/gallery/download/405.pdf: 31. DECC (2009). UK offshore energy strategic environmental assessment; future leasing for offshore wind farms and licensing for offshore oil and gas and gas storage. London, Department of Energy and Climate Change: 861 pp. Defra (2009). Draft guidance on selection and designation of marine conservation zones (Note 1); Draft guidance on the proposed approach to the selection and designation of marine conservation zones under Part 5 of the Marine and Coastal Access Bill. London, UK, The Department of the Environment, Foood and Rural Affairs: 29. Defra (2009). Marine and Coastal Access Bill newsletter; Issue 10, 16th June 2009. F. a. R. A. The Department of the Environment. London, UK: 4. FSIWG (2010). Finding Sanctuary, Inshore Working Group report, meeting 27th July 2010. http://www.findingsanctuary.org/resources/download/901.pdf: 22. FSIWG (2010). Finding Sanctuary, Inshore Working Group report, meeting 28th June 2010. http://www.findingsanctuary.org/resources/download/869.pdf: 21. FSOWG (2010). Finding Sanctuary, Offshore Working Group report, meeting 8th September 2010. http://www.finding-sanctuary.org/resources/download/929.pdf: 17. ISMCZ (2010). Irish Sea MCZ- Stakeholder Group workshop 3, 15 July 2010; workshop outputs, word for word report. http://www.irishseaconservation.org.uk/sites/default/files/ISCZ%20RSG%20Workshop%203%20Word% 20for%20Word%20Report%2015%20July%202010.pdf : 43. Kaiser, M.J., R.E. Blyth-Skyrme, P.J.B. Hart, G. Edwards-Jones & D. Palmer (2007). "Evidence for greater reproductive output per unit area in areas protected from fishing." Canadian Journal of Fisheries and Aquatic Sciences 64: 1284-1289. MPASAP (2010). Finding Sanctuary; assessment of performance against principles. Response by the MPAs Science Advisory Panel to the presentation on 5 July 2010. http://www.findingsanctuary.org/resources/download/895.pdf: 11. NE & JNCC (2010). Additional guidance for regional MCZ projects on planning for areas where licensed, planned or existing socio-economic activities occur. Peterborough, UK, Natural England and the Joint Nature Consevation Committee: 6. NE & JNCC (2010). Marine conservation zone project; additionla guidance for regional MCZ projects on planning for areas where licensed, planned or existing socio-economic activitieis occur. Peterborough, UK, Natural England and the Joint Nature Conservation Committee: 6. NE & JNCC (2010). Marine conservation zone project; ecological network guidance, Version 10. Peterborough, UK, Natural England and the Joint Nature Conservation Committee : 144. ScottishGovernment (2010). "http://scottishparliament.cc/s3/committees/rae/documents/documents/MinisterialStatementfortheMarine andCoastalAccessAct.pdf." TheCrownEstate (2010). Round 3 zone appraisal and planning; a strategic appraoch to zone design, project identification and consent http://www.thecrownestate.co.uk/r3_zone_appraisal_and_planning.pdf : 39. UKGovernment (2009). Marine and Coastal Access Act 2009. H. M. s. S. Office. London, UK.

8 ICHTHYS MARINE, 21/10/10. ISSUES DOCUMENT- SUBJECT TO REVIEW

Benefits and Disbenefits of Co-locating Windfarms and MCZs ISSUES DOCUMENT FOR STAKEHOLDER REVIEW
Thank you for taking the time to read this document. Co-location is an important issue facing windfarm developers, fishermen and other marine stakeholders. Please now consider the draft list of benefits and disbenefits that have been identified, and provide answers to the following questions. Your input will help to refine and improve understanding of this management approach. Please note, that any answers you provide will not be attributed to you unless you specifically request them to be. 1) Is the list of benefits and disbenefits complete, should more be added, or should some be discounted as not being relevant (yes/no)? Complete: Something missing: Delete something:

2) What's missing from the benefits and disbenefits list, or what needs to be deleted? Missing:

Delete::

3) Benefits

How important are the different benefits or disbenefits (please rank in order from 1, highest)? Disbenefits May increase costs for developers... May limit access to fishing grounds.. Turbines may compromise MCZ...... Cables may compromise MCZs........ May require too much compromise.. May affect compensation payments.. Other...............................................

May minimise socio-economic impacts... May support developer-fishing liaison... Consistent with environmental focus.... Restrictions may support conservation.... May support MCZ management efforts. Other.................................................... Other.......................................................

4) Are any of the benefits so great that co-location must definitely be adopted?

5) Are any of the disbenefits so great that co-location should not be considered?

6) Are there any other issues, or points you want to make.

Your name:

Your organisation: Thank you again for your time and attention- your input is appreciated. 9 ICHTHYS MARINE, 21/10/10. ISSUES DOCUMENT- SUBJECT TO REVIEW

Master your semester with Scribd & The New York Times

Special offer for students: Only $4.99/month.

Master your semester with Scribd & The New York Times

Cancel anytime.