In Japanese, frogs make the 'kero kero' sound (ribbit ribbit essentially). So in a cute word play, one of Gero's symbolic animal is the frog–'gero gero!' Our second day in Gero was mostly spent exploring the town's various stores for local snacks–a very worthy endeavor if you're a foodie because there are endless things to try! We woke up to clouds rolling in from the mountains and some light rain, but fear not since our ryokan had already prepared for us large umbrellas for our day of exploration.
Gero on a cloudy day has a mysterious cloudy vibe to it, makes me think about Spirited Away all the more!
A fascinating Pudding Jam we found as we were shopping–you're suppose to spread it onto your bread kind of like a creamy custard spread!
A bite of the Hida Beef meat bun–if only all meat buns taste phenomenal like this!
Stumbling upon our old friend, Charlie Chaplin!
A 'kaeru' shrine, which is Japanese for frog!
Even after multiple snacks and unlimited samples at Gero's many omiyage gift shops, Alex and I were still ready to have lunch after walking around all morning. Tip #5 Check out Gero's many omiyage stores, and don't forget to choose one of the many cute frog-decorated ones! Buying omiyage, Japanese for gifts and sweets, is a tradition the Japanese uphold when they visit a new city–afterwards, you share with your coworkers and family the local snacks from wherever you visited. I love it, it's a delicious custom and perfect excuse to try a bunch of snacks!
Lunch was at a restaurant specialising in Unagi (freshwater eel) and Gyudon, essentially thick slices of sweetly marinated Hida Beef on a bed of rice. Both were absolutely delicious and worth every bite even though we were full half way through the meal! The unagi was tender but crispy on the bottom. With the sweet soy glaze over it, it went amazingly with the rice. I also got a serving of sashimi on the side which was also very good. Alex ordered Gifu Prefecture's famous Hida Beef on a bed of rice–I think it's safe to say we both agreed Hida Beef is some of the highest quality beef we've ever had.
After lunch, we headed back to Yunoshimakan for some foot onsen and afternoon lounging since it was pouring outside by then. The pitter patter of rain, your feet soaked in hot spring waters, and a gorgeous view? I think Yunoshimakan was telling me to become a poet and write a haiku or something–it was such a lovely experience! But of course, we couldn't finish our trip without one last dinner. In short, dinner was sukiyaki with Hida Beef, dipped in a raw egg, vegetables soaked in the sweet soy soup base, and some rice with seafood on the side. It truly was an elaborate dinner set that rendered us unmovable afterwards! Ryokans are always known for its traditional dinner sets and when it's served in your room, there is an art form in the way all the dishes are presented. Beautiful!
Stopping for lunch at a restaurant famous for its Grilled Unagi (freshwater eel) and Gyudong 牛丼–a bed of sticky rice topped with sweetly marinated slices of Hida Beef and sweet sauce, yumm!
Back to the ryokan for some more onsen before the rain–the clouds were rolling in on us!
A collection of seafood delicacies–not for the fainthearted as I had trouble eating some of them, the shell one was a Japanese version of escargot!
More delicacies–shrimpe with ikura, grilled sardines, and some type of liver I couldn't bring myself to try, next time when I'm feeling more lion-hearted!
Ticket from Gero back to Nagoya before going back to Tokyo! The Goldfinch is my current book of choice, it's a phenomenal read!
Gero was a phenomenal hot springs experience we thoroughly enjoyed. Yunoshimakan has its own rooftop hot spring, which overlooks Gero City, so it was all the more lovely! To be honest, we had never heard of Gero, Japan until we stumbled upon it while researching for a place to go that neither of us have been to. If you've traversed across the major Japanese cities like Tokyo, Osaka, and Kyoto, maybe it's time for some quaint town explorations with amazing mountain views!
And in the spirit of Japanese frog sounds, 'gero, gero'!
Liver is the best! You have no idea what you're missing out on 😉 Haven't tried unagi…yet, but those pictures make it look far more appetizing than what I saw in Tokyo so I might just give it a try if I come across it this time around ^-^ And thanks for stopping by!
Thanks for reading! Next time, I'll have to be more adventurous!
Very inspirational! I'd love to explore Japan one day.
Thank you! You definitely should, it's a haven for foodies!
Too many choices indeed! I love that about Japanese shops–they have everything you want!
Thanks much for posting this! I had never heard of Gero either and it looks exactly like the kind of place that hubs and I would love. Maybe you say it in part 1 but how did you find the ryokan?
Thanks so much for reading! I use japanican to search up ryokans to stay at in Japan, I definitely recommend it! Gero's a lovely place that's a little off the beaten path, but definitely worth the visit!
Thanks for the info! I've never used japanican so I'll have to check it out. Hubby and I *love* "off the beaten path*. So happy for your tip!
I'll be there in Nov & am booked to stay at the same ryokan. Thanks !


Born in Bendigo, educated in Melbourne and later marooned in Sydney, Peter Lalor is an award winning author and journalist. He has written a number of books including the best-selling Ned Kelly True Crime prize-winning Blood Stain and The Bridge, a history of The Sydney Harbour Bridge. A cricket writer for The Australian newspaper he has worked as a journalist for 25 years.
Phillip Hughes gave his life to cricket. And cricket gave Phillip Hughes his life.


In his story on upcoming Palestinian elections, "Israel to Disrupt Palestinian Vote if Hamas Runs," (Sept. 17, 2005), reporter Joel Brinkley portrayed as a unilateral Israeli demand what is in fact a Palestinian obligation under the Oslo Accords to bar terror groups from elections. In a further display of bias Brinkley ignored all other Palestinian obligations under the various peace plans as well, but did note an alleged Israeli violation of the Road Map.
Mr. Sharon said Israel could choose not to remove roadblocks and checkpoints that would block Palestinians from the polls and make it hard for Palestinians in Jerusalem to vote, among other steps, if Hamas, which calls for Israel's destruction, takes part.
His remarks stunned Palestinian leaders. Hamas is taking part in municipal elections now under way and has made clear its intention to field candidates in January.
(2) pursue the implementation of their aims by unlawful or nondemocratic means.
Hamas leaders have taken responsibility for some of the deadliest suicide bombings against Israeli civilians in recent years.
If suicide bombings against civilians are not "unlawful means," then what would be?
But Mr. Abbas has signed a peace deal with Hamas and a similar group, Islamic Jihad, and says the best way to ease them away from violence is to urge them into the political mainstream. Israeli and American officials say that until the groups give up their arms and renounce terrorism, they have no place in the democratic process.
Thus under Oslo, the Palestinians were obligated to dismantle the armed gro up Hamas, not reach "peace deals" with it.
"The settlements will be the last phase," he said.
The peace plan, or "road map," that the United States and its allies proposed in 2003 and which Israel has endorsed, calls on Israel to freeze settlement growth as one of the very first steps. Several times on Friday Mr. Sharon repeated that he supported the road map and intended to follow it.
By ignoring Palestinian obligations under the various peace plans, and by reporting only an alleged Israeli violation, Brinkley undoubtedly leads many readers to believe that only Israel has obligations under these plans, and that therefore only Israel is to blame for the absence of peace. Brinkley may well believe this false picture, but as a journalist he has an obligation to keep such views out of the news pages.
While there's no doubt the PA routinely violates its peace-plan obligations, by publishing Brinkley's skewed and inaccurate dispatches the New York Times violates its journalistic obligations to avoid bias and give readers the full truth.


text:
Die Venusmuscheln (Veneridae) sind eine Familie von Muschelarten in der Ordnung Venerida. Die Familie umfasst zwölf noch nicht abgesicherte Unterfamilien mit zahlreichen Gattungen – die ebenfalls noch nicht taxonomisch abgesichert sind – und über 400 Arten, wovon die meisten essbar sind.

Die Venusmuscheln kommen weltweit in allen Küstengewässern vor, meist in und auf sandigem Untergrund. Der Schwerpunkt der Verbreitung liegt in den warmen Meeren. Die ältesten Vertreter der Familie stammen aus dem Valanginium (Unterkreide).

Beschreibung

Typische Schalenmerkmale
 Der Wirbel befindet sich vor der Schalenmitte und erscheint meist etwas eingerollt. Dadurch entspricht die Schalenform etwa dem Profil einer Mainzelmännchenmütze.
 Typisch für die Schalenskulptur sind konzentrische Rippen oder Rillen. (Ausnahme in Europa: Timoclea ovata). Sie unterscheiden sich dadurch von den radial gerippten verwandten Herzmuscheln.
 Heterodontes Schloss

Mythen und Geschichten

In der Antike galt die Muschel allgemein als geschlechtsloses Wesen, das aus dem Meerschaum entstand. Auch Aristoteles war von dieser Ansicht, die in der Folge bis ins späte Mittelalter weitergegeben wurde, überzeugt. Nach der griechischen Mythologie wurde Aphrodite bzw. die römische Venus u. a. aus dem Meerschaum und in der Folge aus einer Muschel geboren.

Der Name der Venusmuscheln wird auch von ihrer Gestalt abgeleitet. Die leicht eingerollte Grundform der Venusmuscheln ähnelt angeblich als Ganzes mit etwas Vorstellungskraft dem Bauchnabel der Schönheitsgöttin Venus, während die Ansicht von Wirbel und Ligament von dorsal mit viel Einbildungskraft der Vulva einer Frau gleicht.

Als das Porzellan nach Europa gelangte, wurde es so angeblich nach "porcellano", einem italienischen Spitznamen für die Glänzende Venusmuschel (Callista chione) benannt. Die Schalen dieser Art glänzen innen und außen so, als ob sie poliert wären – so wie Porzellan. "Porcellano" (übersetzt "Schweinchen") leitet sich von der oval-bauchigen und bräunlich-rosa glänzenden Schale dieser Venusmuschel ab.

Systematik

Phylogenie der Veneridae
Nach Kappner und Bieler sind Chioninae und Venerinae zwei getrennte Gruppen, wobei die Gattungen Chamelea, Clausinella, Tawera und Timoclea neu zu den Venerinae zugeordnet werden. Morphologisch unterscheiden sich die beiden genannten Gruppen durch getrennte Siphone und (meist) einen vorderen Nebenzahn bei den Venerinae sowie verschmolzene Siphone und keinen vorderen Nebenzahn bei den Chioninae.

Weitere Untersuchungen zur Klärung der Phylogenie sind notwendig.
Gattungen sind in Klammern hinter den Unterfamilien angegeben.

Unterfamilien
 Chioninae
 Circinae
 Clementinae
 Cyclininae oder Cyclinae
 Dosiniinae
 Gemminae
 Meretricinae
 Japanische Venusmuschel (Meretrix lusoria)
 Pitariinae
 Samarangiinae
 Sunettinae
 Tapetinae
 Gegitterte Venusmuschel (Ruditapes decussatus)
 Venerinae

Liste der Gattungen

Hier eine Auflistung der Gattungen von Venusmuscheln (möglicherweise unvollständig) ohne Berücksichtigung der Gruppierung nach Unterfamilien:

 Agriopoma Dall, 1902
 Amiantis Carpenter, 1884
 Anomalocardia Schumacher, 1817
 Callista Poli, 1791
 Chamelea Morch, 1853
 Chione Megerle von Mühlfeld, 1811
 Chionista Keen, 1958
 Circomphalus Klein, 1853
 Clausinella J. E. Gray, 1851
 Gebänderte Venusmuschel (Clausinella fasciata (da Costa, 1778))
 Compsomyax Stewart, 1930
 Cyclinella Dall, 1902
 Dosinia Scopoli, 1777
 Artemismuschel (Dosinia exoleta)
 Glatte Artemis (Dosinia lupinus)
 Gafrarium Roding, 1798
 Gafrarium pectinatum (Linnaeus, 1758)
 Gemma Deshayes, 1853
 Globivenus Coen, 1934
 Gouldia C. B. Adams, 1847
 Gouldia minima (Montagu, 1803)
 Humilaria Grant and Gale, 1931
 Irus Schmidt, 1818
 Irusella Hertlein and Grant, 1972
 Liocyma Dall, 1870
 Lirophora Conrad, 1883
 Macrocallista Meek, 1876
 Mercenaria Schumacher, 1817
 Nördliche Venusmuschel (Mercenaria mercenaria)
 Nutricola Bernard, 1982
 Parastarte Conrad, 1862
 Periglypta Jukes-Browne, 1914
 Pitar Römer, 1857
 Protothaca Dall, 1902
 Psephidia Dall, 1902
 Puberella Fischer-Piette and Vukadinovic, 1977
 Saxidomus Conrad, 1837
 Tapes Muhlfeld, 1811
 Timoclea Brown, 1827
 Ovale Teppichmuschel (Timoclea ovale (Pennant, 1777))
 Tivela Link, 1807
 Transennella Dall, 1883
 Venerupis Lamarck, 1818
 Getupfte Teppichmuschel (Venerupis corrugata (Gmelin, 1791))
 Ventricolaria Keen, 1954
 Venus Linnaeus, 1758
 Raue Venusmuschel (Venus verrucosa Gmelin, 1791)

Einige fossile Gattungen:
 Aeora Conrad, 1870 (Kreide)
 Anofia Reyment, 1955 (Oberkreide)
 Loxo Dailey & Popenoe, 1966 (Oberkreide)
 Naulia Cox, 1952 (Oberkreide)
 Rohea Marwick, 1938 (Oligozän)
 Septeuilia Cossmann, 1914 (Eozän)

Siehe auch
 Quahog Parasite Unknown, einzelliger Parasit der Nördlichen Venusmuschel (Mercenaria mercenaria)

Literatur
 Isabella Kappner, Rüdiger Bieler: Phylogeny of venus clams (Bivalvia: Venerinae) as inferred from nuclear and mitochondrial gene sequences. In: Molecular Phylogenetics and Evolution. Bd. 40, Nr. 2, 2006, , S. 317–331, .
 Michael Amler, Rudolf Fischer, Nicole S. Rogalla: Muscheln (= Haeckel-Bücherei. Bd. 5). Enke im Thieme-Verlag, Stuttgart 2000, ISBN 3-13-118391-8.
 Rüdiger Bieler, Paula M. Mikkelsen: Bivalvia – a look at the Branches. In: Zoological Journal of the Linnean Society. Bd. 148, Nr. 3, 2006, , S. 223–235, .
 Victor Millard: Classification of the Mollusca. A Classification of World Wide Mollusca. Eigenverlag, Rhine Road Südafrika 1997, ISBN 0-620-21261-6.

Weblinks

Einzelnachweise

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Steven Spielberg Hires Coen Brothers to Write Thriller
Steven Spielberg has been lining up projects left and right, but one might become the front-runner for his next movie with this latest announcement: Joel and Ethan Coen have been hired to write Spielberg's currently untitled Cold War thriller, which is tentatively set to star Tom Hanks.
Damon Houx
New 'Inside Llewyn Davis' Trailer: The Coen Brothers Hit Up the '60s Folk Scene
There are no filmmakers more consistent in churning out masterpieces on a regular basis than Joel Coen and Ethan Coen, whose filmography is almost entirely made up of great films, underrated gems and, um, 'The Ladykillers.' Every new Coen Bros. film is an event and 'Inside Llewyn Davis' is no differ…
'Inside Llewyn Davis' Trailer: The Coen Brothers Folk It Up
It's arguable that the Coen Brothers are the greatest working directors of our day. Sure, there's Steven Spielberg and Quentin Tarantino (among others), but Joel and Ethan Coen have delivered some of the best films of all time, and some of the greatest films of the last ten years. Their latest, 'Ins…
'Inside Llewyn Davis' and 'Blue is the Warmest Color' Win Top Prizes at Cannes
In what should come as a surprise to no one, the latest film from the Coen brothers took home a big prize at the 2013 Cannes Film Festival. In what may be a little more surprising, a French coming-of-age film about two lesbians took home the grand prize.
Angelina Jolie's 'Unbroken' is Being Re-Written by The Coen Brothers
Angelina Jolie's latest project just got way more interesting. Her second directorial effort will come with a script from Oscar winners Joel and Ethan Coen, as they've just been hired to re-write Jolie's upcoming film 'Unbroken.'
Joel and Ethan Coen's 'Gambit' Gets Two Posters and Six Seconds of Colin Firth Without Pan…
It may be a while before we see 'Gambit,' the Joel and Ethan Coen-scripted remake of the 1966 caper starring Colin Firth and Cameron Diaz, but we've got a few seconds of footage and two posters to show you that should -- maybe, probably -- hold you over until then.
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Writing good romance is hard- it has so many pitfalls to avoid, so many tropes to grapple with and principles to keep in mind, that experience is necessary.
Writing actual platonic friendships between a male and female character is even harder.
With fewer art programs in schools these days on average, the next generation of budding artists looks bright.
This Sunday's #Twitter_Feature is Bottomless waitress by Ozoneocean and Banes!
Check out the entire thread in a twitter moment here!
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Comicraft fonts on sale Jan. 1 ONLY, Cintiq auction, milestones and stuff!
Well, I have. And here it is. In no particular order whatsoever.
Today, Genejoke's Malefic Tales reaches 75 pages!
Also in the 75 pages milestones ballpark (it's at least 1 or 2 pages over by now because I am slow) is I am by I Am The 1337 Master!
Look out behind you! Is that a NEWS?


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Last year Replica Olisaemeka Udoh Jersey , when Florida State running back Dalvin Cook fell out of the first round of the NFL draft, the Vikings made an aggressive trade to move up early in the second round to get him and install him as the heir apparent to future Hall of Famer Adrian Peterson.Through the first four games, it looked like one of the best trades GM Rick Spielman ever made, as Cook started out with over 350 yards rushing in his a little over three and a half games. In his fourth game, though, he tore his ACL against Detroit, and was lost for the season.It was thought that he would be an integral cog in the 2018 offense, but he started slow, only rushing for 78 yards in his first two games. He hurt his hamstring in week three in a loss to Buffalo, aggravated his injury against the Los Angeles Rams a week later, and has been out ever since.All signs were pointing to him playing against Arizona, but he tweaked his hamstring again during warmups and was a late scratch. Now Olisaemeka Udoh Jersey nfl draft , comes this from Vikings ESPN beat reporter Courtney Cronin:If true, Cook will miss two games before the Vikings break for their bye week, against the Saints this Sunday night and then Detroit. Although it's another tough break for Cook, who's missed 14 games in his two year career, the decision by the Vikings to keep Latavius Murray has really paid off. Murray has rushed for 224 yards and three touchdowns in the last two games, including a career high 155 yards against Arizona two weeks ago. In last Sunday's 37-17 win over the New York Jets, Murray ran for 69 (nice) yards, and had touchdown runs of 11 and 38 yards.Hamstrings can be tricky injuries, and although it's frustrating, the Vikings can afford to keep Cook sidelined until he's fully healthy, and ready for the stretch run. For now, they'll just ride the Tay Train. 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"I wasn't trying to force things, but I was finding the ball, and in the same breath, now that I watch the film, there's definitely things that I could've done to put our team in better positions at times."The coaching staff would concur with that.Early in the second quarter, when Eagles quarterback Carson Wentz rolled out to his left on third-and-6, Kendricks let his man, wide receiver Nelson Agholor, slip behind him as he drifted forward. Leaping to bat the pass was his only play, and that's what he did, nearly intercepting the ball after whirling around to try to find it.Running back Miles Sanders also caught a 32-yard touchdown pass on a wheel route out of the backfield that left Kendricks flat-footed in the second quarter."He was back to the rookie Eric Kendricks. Then he settled down and got back to playing really well. He just has to stay disciplined in his coverage Olisaemeka Udoh Jersey nfl draft ," Zimmer said. 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ScHoolboy Q returns with new album CrasH Talk: Stream
Fifth studio effort features Kid Cudi, 21 Savage, Lil Baby, and more
ScHoolboy Q, photo by Philip Cosores
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Spanning a total of 14 songs, today's LP sees the South Central LA rapper collaborating with the likes of Kid Cudi, 21 Savage, Lil Baby, Ty Dolla $ign, and YG. It was previewed early with singles "CHopstix", "Numb Numb Juice", and "CrasH".
(Read: The 10 Most Anticipated Hip-Hop Albums)
CrasH Talk serves as Q's fifth full-length overall and the follow-up to 2016's stellar Blank Face LP. According to the MC, he ended up scrapping multiple albums before finally settling on CrasH Talk, and even then, he chose to delay its release following the death of close friend and colleague Mac Miller last fall.
Also in the years since Blank Face, Q has put out a string of one-off collaborations with Kamaiyah ("Addicted to Ballin'") and Future ("Code of Honor"). Additionally, Q contributed to the Black Panther soundtrack and performed as part of Top Dawg's Championship Tour alongside Kendrick Lamar and SZA.
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CrasH Talk Artwork:
CrasH Talk Tracklist:
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The Cranberries share final album In the End: Stream
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Manning: Mueller should be fired, politically weaponized FBI and Justice Dept. is 'un-American'
December 5, 2017 by press
Dec. 5, 2017, Fairfax, Va.—Americans for Limited Government President Rick Manning today issued the following statement urging Deputy Attorney General Rod Rosenstein to fire Special Counsel Robert Mueller and to end his investigation:
"Several extremely troubling revelations have become known in recent weeks about the orchestrated attempt to take down President Donald Trump before he ever took office.
"Lee Smith at the Federalist alleges that Fusion GPS has been paying reporters to publish political attack pieces based on manufactured sources to delegitimize the Trump campaign and then the official transition after he won the election in late 2016. This sheds new light on the climate in the media prior to the publication of the original story that then-President Elect Donald Trump had been briefed by the FBI on the Fusion GPS-Christopher Steele dossier alleging Trump-Russia collusion, which then became the basis for reporting on it. Laura Jarret and Evan Perez CNN revealed that it was an FBI counterintelligence official, Peter Strzok, who edited an exoneration into what was supposed to be the final report on the Clinton email investigation well in advance of Hillary Clinton's interview with the FBI that, as Fox News' Catherine Herridge reports, he was leading. The Daily Caller's Chuck Ross also reports that Strzok was the same agent who questioned Cheryl Mills on the private Clinton email server, who along with other Clinton aides was later granted immunity. Sara Carter at Hannity.com reports that Strzok was also the same agent who questioned former National Security Advisor Michael Flynn about his conversations with multiple ambassadors, a meeting which was set up by Deputy FBI Director Andrew McCabe under false pretenses as a routine discussion of security procedures at the White House. Couple all this with the fact that, as reported by the Washington Post's Adam Entous, Devlin Barrett and Rosalind Heldermant, the DNC and the Hillary Clinton campaign via law firm Perkins Coie paid for the Fusion GPS-Christopher Steele dossier that originated the unsubstantiated allegations that the Trump campaign colluded with Russia to hack the DNC and put the emails on Wikileaks, which then became one of the bases for the FBI witch hunt, including in obtaining FISA court warrants. The FBI under former Director James Comey even reportedly offered to pay Steele to continue this work.
"It is anti-American to have a politically weaponized FBI and Justice Department. The evidence now available indicates that higher-ups at the FBI would pursue any measure in their attempts not only to prop up Hillary Clinton, but to take down President Trump at any cost. Since the entire Mueller investigation is the fruit of this poisonous tree, the only course Deputy Attorney General Rod Rosenstein can pursue must be to fire Mueller and end this political coup in order to restore the rule of law."
"Hillary Clinton and the DNC funded the fake Trump-Russia collusion dossier, turned it into an FBI inquisition, surveillance and then attempted coup," By Robert Romano, Oct. 26, 2017 http://netrightdaily.com/2017/10/hillary-clinton-dnc-funded-fake-trump-russia-collusion-dossier-turned-fbi-inquisition-surveillance-attempted-coup/
Filed Under: Press Releases Tagged With: fisa-court


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Vedder Thinking | Articles
SEC Finalizes Updates to Advertising and Cash Solicitation Rules
Newsletter/Bulletin | January 5, 2021
On December 22, 2020, the U.S. Securities and Exchange Commission ("SEC") finalized a new "Marketing Rule" under the Investment Advisers Act of 1940 (the "Advisers Act") that overhauls the traditional Advertising Rule under Rule 206(4)-1 and the Cash Solicitation Rule under Rule 206(4)-3. The new Marketing Rule represents a significant change to how investment advisers can market themselves and their products, including how advisers to private funds such as private equity, venture capital and hedge funds can present their performance information. The SEC also has made related amendments to Form ADV, the investment adviser registration form, and Rule 204-2, the books and records rule.
As summarized in the corresponding press release (found here), the new rule merges the Advertising Rule and the Cash Solicitation Rule and replaces the traditional broadly drawn limitations with principles-based provisions designed to accommodate the continual evolution and interplay of technology and advice. The staff of the Division of Investment Management will withdraw decades of no-action letters and other guidance addressing the application of the Advertising and Cash Solicitation Rules, as those positions are either incorporated into the final rule or will no longer apply. A list of such letters will be available on the SEC's website.
The new Marketing Rule was adopted with a number of modifications from the proposed rule published in November 2019. Important differences from the proposal include:
not expanding the definition of advertisements to one-on-one communications
internal review and written approval of advertisements is not required prior to dissemination
no separate requirement for performance advertisements used with retail versus non-retail clients, and
loosening of the requirements for advertisements to display predecessor performance
The Marketing Rule, amended books and records rule, and related Form ADV amendments will be effective 60 days after publication in the Federal Register. The SEC has adopted a compliance date that is 18 months after the effective date to provide a transition period to comply with the amendments.
Vedder Price's Investment Services Group will host a webinar panel discussion concerning the SEC's recent updates to the Advertising and Cash Solicitation Rules on January 15, 2021. The details of the webinar will be announced shortly. Subscribe to our Investment Services group email list to ensure you receive an invitation.
The New Marketing Rule under the Advisers Act
Definition of Advertisement
Under the Marketing Rule, the definition of "advertisement" contains two prongs. The first captures communications that offer advisory services that were traditionally covered by the Advertising Rule. The second prong is designed to capture compensated testimonials and endorsements.
Offering Advisory Services
Under the first prong, the definition includes any direct or indirect communication an investment adviser makes that: (1) offers the investment adviser's investment advisory services with regard to securities to prospective clients or private fund investors or (2) offers new or additional investment advisory services with regard to securities to current clients or private fund investors.
Important Exclusions from the Definition of an Advertisement:
One-on-One Communications. The SEC excluded one-on-one communications from the first prong of the Marketing Rule under most circumstances in response to negative comments regarding the proposed rule. Because of specific concerns raised by hypothetical performance, inclusion of hypothetical performance information would not qualify for the one-on-one exclusion unless it was provided in response to an unsolicited investor request or to a current or prospective investor in a private fund advised by the investment adviser.
Extemporaneous, live, oral communications
Information contained in a statutory or regulatory notice, filing or other required communication and
Communications regarding registered investment companies (i.e., closed-end funds, ETFs and mutual funds) and business development companies
Compensated Testimonials and Endorsements
Under the second prong, the definition generally includes any testimonial or endorsement for which an adviser provides compensation. This includes cash and non-cash compensation paid directly or indirectly by the adviser (e.g., directed brokerage, awards or other prizes, and reduced advisory fees). Importantly, compensated endorsements and testimonials will satisfy the definition of advertisement regardless of whether the communication is made orally or in writing or to one or more persons.
In perhaps the most stunning reversal of the prior advertising regime but consistent with the proposed rule, the Marketing Rule now permits the use of testimonials and endorsements in an advertisement provided the adviser complies with certain disclosure, oversight and disqualification provisions. We can only imagine the number of possible celebrity endorsements in the future. Adviser Chief Compliance Officers should get ready for questions. Below are the relevant definitions.
The final definition of Testimonial includes any statement by a current client or private fund investor about the client's or private fund investor's experience with the investment adviser or its supervised persons.
The definition of Endorsement includes any statement by a person other than a current client or private fund investor that indicates approval, support or recommendation of the investment adviser or its supervised persons or describes that person's experience with the investment adviser or its supervised persons.
Testimonials and endorsements also include statements in an advertisement about an adviser or its supervised person's qualities (e.g., trustworthiness, diligence or judgment) or expertise or capabilities in other contexts, when the statements suggest that the qualities, capabilities or expertise are relevant to the advertised investment advisory services. The definitions of testimonial and endorsement also include solicitation and referral activities drawn from the definition of solicitor.
There are four primary conditions for testimonials and endorsements:
Disclosure. Advertisements must clearly and prominently disclose whether the person giving the testimonial or endorsement (the "promoter") is a current client or investor and whether the promoter is compensated. Additional disclosures are required regarding compensation arrangements and conflicts of interest. There are exceptions from the disclosure requirements for SEC-registered broker-dealers under certain circumstances as noted below. In a break from the
Cash Solicitation Rule, the disclosure requirement does not require delivery of a client disclosure by the promoter, as the obligation rests with the adviser to deliver or have a reasonable belief that the promoter delivers the required information. In another break from the Cash Solicitation Rule, advisors will no longer need to obtain a signed client acknowledgment.
Written Agreement. An adviser must enter into a written agreement with promoters, except where the promoter is an affiliate of the adviser or the promoter receives de minimis compensation (i.e., $1,000 or less, or the equivalent value in non-cash compensation, during the preceding 12 months).
Disqualification. The rule prohibits certain "ineligible persons" from acting as promoters, subject to exceptions where other disqualification provisions apply. Notably, the disqualification provision does not prohibit persons for actions prior to the effective date of the Marketing Rule; provided, that such person was not otherwise disqualified under the former Cash Solicitation Rule. The disqualification provisions under the Marketing Rule will not apply to a testimonial or endorsement by a person covered under the "bad actor" provisions of Regulation D for a Rule 506 securities offering and whose involvement would not otherwise disqualify the offering under Rule 506. Ineligible persons under the Marketing Rule include persons (and certain associated persons) subject to a disqualifying Commission action or disqualifying event.
A disqualifying Commission action includes an SEC opinion or order barring, suspending or prohibiting a person from acting in any capacity under the federal securities laws.
A disqualifying event includes certain criminal convictions and orders, including those of other governmental agencies such as the CFTC, that occurred within 10 years prior to the person disseminating a testimonial or endorsement.
Oversight and Compliance. In providing any testimonial or endorsement the adviser must have a reasonable basis for believing that the testimonial or the endorsement complies with the requirements of the Marketing Rule, including the general prohibitions described above. The written agreement noted above is part of the adviser's oversight obligations. Adviser Chief Compliance Officers will want to take note of these requirements.
Exemptions for Testimonial and Endorsements:
De Minimis Compensation. A testimonial or endorsement disseminated for no compensation or de minimis compensation (i.e., less than $1,000) is not required to comply with the written agreement requirement or the disqualification provisions, but must comply with the disclosure and oversight provisions.
Affiliated Personnel. A testimonial or endorsement by the adviser's partners, officers, directors or employees, or a person that controls, is controlled by, or is under common control with the investment adviser, or is a partner, officer, director or employee of such a person is not required to comply with the disclosure or written agreement requirements, but must comply with the oversight and disqualification provisions. In addition, the affiliation must be readily apparent or disclosed at the time the testimonial or endorsement is disseminated.
Broker-Dealers. A testimonial or endorsement by a broker-dealer will be exempt from the disqualification provisions under the Marketing Rule so long as the broker is not subject to statutory disqualification under Section 3(a)(39) of the Securities Exchange Act of 1934. In addition, broker-dealers will be exempt from certain of the the disclosure requirements of the Marketing Rule for a recommendation subject to Regulation BI for retail clients and subject to certain conditions for non-retail clients.
Third-Party Ratings
The new rule permits the use of third-party ratings in an advertisement, subject to certain disclosure and other criteria pertaining to the preparation of the rating. The term "third-party rating" is defined as "a rating or ranking of an investment adviser provided by a person who is not a related person (as defined in the Form ADV Glossary of Terms), and such person provides such ratings or rankings in the ordinary course of its business."
An investment adviser may not include a third-party rating in its advertisement unless the adviser has a reasonable basis for believing that any questionnaire or survey used in the preparation of the third-party rating is structured to make it equally easy for a participant to provide favorable and unfavorable responses, and is not designed or prepared to produce any predetermined result.
An investment adviser must clearly and prominently disclose, or the investment adviser must reasonably believe that the third-party rating clearly and prominently discloses: (1) the date on which the rating was given and the period of time upon which the rating was based; (2) the identity of the third party that created and tabulated the rating; and (3) if applicable, that compensation has been provided directly or indirectly by the adviser in connection with obtaining or using the third-party rating (the "disclosure requirement"). In order to be clear and prominent, the disclosure must be at least as prominent as the third-party rating.
Performance Advertising
The Marketing Rule provides some much needed clarity on the use of gross, net, hypothetical, related and extracted performance. While the Marketing Rule varies from the proposed rule in that the retail versus non-retail distinction has been removed, the Marketing Rule largely adopted the proposed rule provisions regarding performance advertising, which generally codified prior SEC no-action letter guidance.
Gross and Net Performance. Gross performance may not be used in any advertisement unless the advertisement also presents net performance: (1) with at least equal prominence to, and in a format designed to facilitate comparison with, the gross performance; and (2) calculated over the same time period, and using the same type of return and methodology, as the gross performance. The requirement of showing net performance applies to all advertisements versus just retail advertisements as proposed. With the retention of the one-on-one communication exclusion from the definition of an advertisement, this basically leaves in place the gross and net performance provisions from prior SEC no-action letters. In addition,
Model Fees. Model advisory fees can be used to calculate net performance so long as the performance is no better than with the actual fees applied.
Time Periods. Other than for private funds, performance results must include results for one-, five- and 10-year periods with equal prominence. Performance must be presented at least as of the most recent calendar year-end. If the portfolio did not exist for all periods, then performance is to include since inception performance. These requirements are a minimum and additional time periods can be disclosed.
Statements Regarding SEC Approval. Consistent with the proposed rule, the Marketing Rule prohibits any statement, express or implied, that the calculation or presentation of performance results in the advertisement has been approved or reviewed by the SEC in any advertisement containing performance results.
Related Performance. Related performance results of one or more related portfolios may only be used if the presentation includes all related portfolios with substantially similar investment policies, objectives and strategies as those being offered in the advertisement, with limited exceptions if the excluded related performance would not result in materially higher performance and does not alter the presentation of any applicable time periods.
Extracted Performance. Performance results of a subset of investments extracted from a portfolio may only be used if the advertisement provides, or offers to provide promptly, the performance results of the total portfolio.
Hypothetical Performance. Hypothetical performance (which does not include performance generated by interactive analysis tools) may only be used if the adviser adopts and implements policies and procedures reasonably designed to ensure that the performance is relevant to the likely financial situation and investment objectives of the intended audience and the adviser provides (or, if the intended audience is an investor in a private fund, offers to provide promptly) the criteria used and assumptions made in calculating the hypothetical performance, and the risks and limitations of using hypothetical performance in making investment decisions.
Predecessor Performance. Predecessor performance may only be used in an advertisement when: (1) the person or persons primarily responsible for achieving the prior performance results manage accounts at the advertising adviser; (2) the accounts managed at the predecessor investment adviser are sufficiently similar to the accounts managed at the advertising investment adviser that the performance results would provide relevant information to clients or investors; (3) all accounts that were managed in a substantially similar manner are advertised unless the exclusion of any such account would not result in materially higher performance and the exclusion of any account does not change the presentation of any applicable time periods prescribed under the Marketing Rule; and (4) the advertisement clearly and prominently includes all relevant disclosures, including that the performance results were from accounts managed at another entity. The adviser must have access to the books and records underlying the predecessor performance and be able to provide them upon demand to the SEC.
Implementation of the above performance requirements is likely to have significant impacts on advisers. Advisers should start evaluating required changes now.
General Prohibitions under Marketing Rule
Consistent with the proposed rule, the Marketing Rule will prohibit the following advertising practices:
making an untrue statement of a material fact, or omitting a material fact necessary to make the statement made, in light of the circumstances under which it was made, not misleading
making a material statement of fact that the adviser does not have a reasonable basis for believing it will be able to substantiate upon demand by the SEC
including information that would reasonably be likely to cause an untrue or misleading implication or inference to be drawn concerning a material fact relating to the adviser
discussing any potential benefits without providing fair and balanced treatment of any associated material risks or limitations
referencing specific investment advice provided by the adviser that is not presented in a fair and balanced manner
including or excluding performance results, or presenting performance time periods, in a manner that is not fair and balanced
including information that is otherwise materially misleading.
As noted above, the new Marketing Rule contains a number of differences from the proposed rule originally announced in November 2019. For example, the definition of an advertisement does not include all communications between an adviser and one person (with the exception of many, but not all, communications referencing hypothetical performance). In contrast to the proposed rule, the definition of an advertisement in the final rule no longer includes communications that merely "promote" an adviser's services. The definition has been narrowed to communications of actual offers of investment advisory services that are "with regard to securities." The final rule also does not include a one-size-fits all pre-review and approval requirement of all adviser marketing materials before dissemination, but defaults to the existing compliance rule. With the increase of the de minimis compensation amount from $100 to $1,000 for promoters, as well as the broader set of exemptions, advisers should be freer to make use of testimonials and endorsements. The incorporation of the Cash Solicitation Rule into the Marketing Rule will also ease compliance burdens when using promoters. Overall, the final rule contains many improvements to the benefit of advisers.
Although the final rule represents a unanimous vote, Commissioners Lee and Crenshaw noted in their joint public statement that the unanimous vote should not be regarded as a consensus about how best to protect investors from the risks of misleading adviser marketing. The two commissioners cite that the commenter objections to the pre-review requirement were appropriately mitigated by the narrowing of the definition of an "advertisement." On hypothetical performance, they also took umbrage that the final rule includes "unjustifiable" carve-outs for communications containing hypothetical performance in response to unsolicited requests from retail investors and all one-on-one communications with prospective or current investors in private funds. Specifically for private fund investors, the two commissioners expressed concern that private fund advisers could present hypothetical performance even absent any investor request.
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Vedder Thinking | Articles SEC Finalizes Updates to Advertising and Cash Solicitation Rules
Joseph M. Mannon
jmannon@vedderprice.com
Maureen A. Miller
mmiller@vedderprice.com
Robert M. Crea
rcrea@vedderprice.com
Jeff VonDruska
jvondruska@vedderprice.com
Broker/Dealer
Private Equity and Hedge Funds


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Andres G. Mendoza
Andy Mendoza represents clients in the areas of joint ventures, private investment funds, mergers and acquisitions, securities, and corporate governance.
Andy focuses his practice on representing clients in real estate joint venture transactions, private placements and real estate private equity fund formations. Andy represents real estate sponsors and their financial partners in the formation of investment partnerships –whether in the form of one-off joint ventures, programmatic relationships or strategic platforms – and the development and execution of their business strategies, including in connection with the negotiation of venture documentation and acquisition transactions, involving multifamily, retail, office, hospitality, industrial, and other asset classes.
Andy represents fund sponsors and investors in connection with structuring, forming, investing in and offering private equity funds. Andy has also represented public and private companies in a broad range of transactions including mergers, acquisitions, dispositions, tender offers, joint ventures, private placements, and private fund formations.
Joint Venture:
Represented a developer in a programmatic joint venture with one of the largest homebuilding companies in the United States.
Real Estate Private Equity Firms:
Represent a self-storage operator in multiple programmatic joint ventures with real estate private equity firms.
Luxury Hotel:
Represented an investor in a joint venture for the development of a luxury hotel in the Dominican Republic.
Multi-Family Properties:
Represented a sponsor in various joint ventures related to the acquisition of multi-family properties throughout the U.S.
Private Equity Fund:
Represented a private equity fund in various joint ventures related to the acquisition of office buildings in several different states.
Assisted Living Facility:
Represented an investor in a joint venture for the development of an assisted living facility outside of Philadelphia.
Real Estate Investments:
Represented sponsor focused on general real estate investments primarily in the State of Florida with the formation and structuring of 4 real estate private equity funds.
Real Estate Debt and Equity Funds:
Represented sponsor in the formation and structuring of real estate debt and equity funds with capital commitments in excess of $1 Billion.
Private Equity Funds:
Represented sponsors in the formation of private equity funds for the making of real estate bridge loans and investment in Community Development District Bonds.
Published Work and Lectures
Miami Finance Forum, Moderator, "The South Florida Private Equity Deal Makers - Part II, A Discussion with Key Private Equity Firms and Portfolio Company Executives," October 24, 2014
American Sleep Apnea Association, Inc. Board of Directors, Member
Honors and Distinctions
The Best Lawyers in America 2018-2023, Listed in Florida for Real Estate Law; Banking and Finance Law
Super Lawyers Magazine, 2013, Listed in Florida as a "Rising Star" for Mergers & Acquisitions
The Legal 500, 2016, Recommended for Real Estate & Construction - Real Estate; M&A - Middle Market (Sub-$500 Million)
Areas of Experience
Corporate Restructuring and Insolvency
M&A and Private Equity
Multifamily Development and Acquisitions
Data Centers and Digital Infrastructure
Renewable Energy and Electric Power
J.D., University of Miami School of Law, summa cum laude
M.B.A., University of Miami, 2002
B.A., University of Virginia, 1997
71 Akerman Real Estate Lawyers Named to The Best Lawyers in America 2023 Guide
Akerman Guides Purchase of The Ziggurat in Sacramento's Biggest Real Estate Deal Since the Start of the Pandemic
Record Number of Akerman Lawyers Across the United States Named to The Best Lawyers in America 2022 Guide


It's a bit out of date, but this page might be a good place to start.
I tried to use it to find the one the OP was looking for, but Ctrl-F-ing the keywords didn't seem to come up with anything.
Damn, I don't know either, but I'd also like to know.
This thread is intriguingly apophatic.
I missed it completely. I hope someone knows what it was and where to get a copy. I love the idea of an OSR sword 7 sorcery game with no player spell casters.
Never heard of it, beyond I'm thinking it was a 3E hack?
Are you thinking of the Barbarians of Lemuria variant The BoL Hack? It's a very stripped down version of BoL, but uses a d20. There's a Magician class, but most will be NPC's since most magic is evil.
Definitely not, as the timeline doesn't match up. And this was BIG on "no your PCs aren't gonna be spellcasters" Really the tone is probably a big part of why I initially deleted it.
Maybe you were thinking of ZEFRS - Zeb Cook's Fantasy Roleplay system, the stripped down system used in the original TSR Conan RPG?
No, but I have been meaning to give that game another look.
maybe and Crypts & Things?
... Jk. first thing that comes to mind is Carcosa.
Both have spellcasting classes. In fact Carcosa's only class is a spellcaster. I don't know why it came to your mind.
Also Carcosa isn't a game, it's a supplement to OD&D (initially) and LotFP (currently).
It sounds an awful lot like Iron Heroes, except that Iron Heroes isn't an OSR game, and I don't think it was ever free.
I mean is Iron Heroes worth taking a look at if I, and let me be clear (again), hate 3E... I have used ranting and raving about 3E to help me finish the last leg of a 17 hour drive at night in a snowstorm.
But I have a question for you... do you know of a place that has a two or three sentence summary of each of those many games? Because I'm looking at picking up another OSR type game or two, but I don't quite know where to start.
Really I have a pretty good knowledge of OSR games, what specifically are you looking for?
Yes if it was that easy I'd have found it. I was hoping the laundry list of OSR games in the OP would demonstrate that this was a Test For Champions.
I KNOW, right? I really kick myself for having deleted it. I don't delete anything anymore.
It's a neat 3E hack, and supports awesome fighter-types slashing their way through the Monster Manual without the need for magic items, but at the end of the day it's a 3E hack. If you hate 3E, I doubt it will change your mind.
I thought of that, but isn't anything there about having NPC Sorcerer-Kings of the like. Cool little game, though.
And the OP mentioned it in the caveat so doubly dumb I am. Ah well.
Just printed out ZeFRS, gonna give it a read thru.
mmm... I think I may have encountered this on a blog I retrived from archive.net recently. let me see what I can find in my cache on other pc.


With the monsoon covering most cotton-growing regions of the country, planting across Maharashtra, Gujarat, Telangana and Andhra Pradesh has picked up pace and farmers are trying to complete sowing operations before the cut-off dates.
Significantly, there has been a major dip in demand for Bt cotton and farmers across the country have shown a marked preference for locally-grown varieties.
"The pace of sowing operations is pretty dynamic and as against the usual 40 lakh hectares that comes under cotton plantation in Maharashtra, it remains to be seen how much area actually comes under cotton since several farmers are also opting for pigeon pea (arhar or tur dal). The cut-off date for cotton sowing is around July 10 and can be extended to July 15, after which the growth of cotton becomes stunted. Therefore, the actual acreage remains to be seen," KR Kranthi, director, Central Institute of Cotton Research (CICR), Nagpur, said. The overall acreage across the country, however, could come down to some 105-110 lakh hectares, he said. Area under cotton cultivation was 119 lakh hectares in 2015-16.
According to the data available with CICR, against the 3,000-odd hectares that usually came under local varieties of cotton last year, this season around 72,280 hectares have come under locally grown varieties in Punjab. Local cotton, which is resistant to diseases like leaf curl virus and pest attacks such as whiteflies, accounted for 7% of the total cotton acreage of 10.17 lakh hectares in north India this year. "CICR expects acreage under local cotton to increase to 25% in the next two to three years. Acreage could have gone up further, if more seeds were made available to farmers this year," Kranthi said.
When CICR initially approached seed companies in April for breeding locally-grown varieties, they had shown a reluctance and were anxious if there would be a demand for such seeds. However, the seed supplies were exhausted soon. In Gujarat as well, farmers are opting for two locally grown varieties — Gossypium herbaceum and G Arboreum, although the final figures are not available yet, officials said.
Before the advent of Bt cotton in India, some 25-26 lakh hectares was under locally-grown varieties and this reduced to almost 2-3 lakh hectares in the last few years, Kranthi said.


text:
Moody's assigns (P)A3 rating to Malaysia Sukuk Global's issuance
KUALA LUMPUR: Moody's Investors Service has assigned a provisional (P)A3 rating to the US dollar-denominated trust certificates (sukuk) issued by Malaysia Sukuk Global Bhd.
In a statement on Monday, Moody's said the rating is assigned to the sukuk as the sukuk certificate holders would effectively be exposed to the Government's senior unsecured credit risk, and not be exposed to the risk of performance of the portfolio assets relating to the certificates.
It said the sukuk also would not have any preferential claim or recourse over the trust assets and the certificate holders could not sell or dispose of any trust assets except as expressly provided for under the transaction documents.
The sukuk certificate holders only have rights against the Government, ranking equally with other senior unsecured obligations as provided in the transaction documents, Moody's said.
"Legal opinions have also confirmed legal, binding and enforceable obligations for the Government," it added.
The (P)A3 rating is at the same level as the Government's long-term local-currency and foreign-currency issuer ratings.
Moody's said the provisional status of the rating would be removed upon completion of the sukuk issuance and its satisfactory review of the final terms and conditions and legal opinions.
Moody's also noted that its sukuk rating did not express an opinion on the structure's compliance with syariah law.
(The Star Online / 11 April 2016)
Moody's assigns (P)A3 rating to Malaysia Sukuk Glo...
Global takaful industry needs uniform standards


The American Society for Cell Biology was first organized at an ad hoc meeting in the office of Keith R. Porter at Rockefeller University on May 28, 1960. In the 1940s, Porter was one of the first in the world to use the revolutionary technique of electron microscopy (EM) to reveal the internal structure of cells. The other early leaders of the ASCB—George Palade, Don Fawcett, Hewson Swift, Arthur Solomon, and Hans Ris—were also EM pioneers. All were concerned that existing scientific societies and existing biology journals were not receptive to this emerging field that studied the cell as the fundamental unit of all life. The ASCB was legally incorporated in New York State on July 31, 1961. A call for membership (at $10 a year) went out, enlisting ASCB's first 480 members. The first ASCB Annual Meeting was held November 2-4, 1961, in Chicago where 844 attendees gathered for three days of lectures, slides, and movies of cellular structure. The results of a mail ballot were read out and Fawcett was declared ASCB's first president.
The ASCB did not remain an EM society. New technologies and new discoveries in molecular biology, genetics, biochemistry, and light microscopy quickly widened the field. Cell biology has continued to expand ever since, extending its impact on clinical medicine and pharmacology while drawing on new technologies in bioengineering, high-resolution imaging, massive data handling, and genomic sequencing. ASCB membership has grown to 9,000 worldwide (with 25% of ASCB members working outside the United States). Annual meetings now draw upwards of 5,000 people. Since 1960, 32 past or current ASCB members have won Nobel Prizes in medicine or in chemistry.


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My project is about whether or not there are heat shocked proteins in yeast that had been heat shocked and whether this can help an older burn. I used Western Blotting to show that heat shocked proteins were found in heat shocked yeast. I also found that the heat shocked yeast reduced the effect of acid on salmon flesh one hour after the burn.


Synopsis: A CJA briefing on the sometimes harrowing experiences of victims, witnesses and defendants in a wide-ranging series of Crown Court cases. Structured Mayhem is a digest of a remarkable piece of research carried by the Institute for Criminal Policy Research. Featuring extensive interviews with court users it furnishes a stark reminder that, for all the progress made in recent years, our courts all too often still cause huge frustration and distress to victims and witnesses, and also defendants.


text:
The US Sold Contaminated Crude Oil From Its Strategic Reserve—Report
Public records request show customer dissatisfaction with Energy Department.
Luke Sharrett/BloombergGetty Images
Three companies that have purchased crude oil from the United States now claim the oil contained unusually high levels of poisonous chemicals, according to Reuters.
Internal Energy Department emails obtained by Reuters show that Royal Dutch Shell, the Australian bank Macquarie Group, and PetroChina International America (the U.S. trading arm of a Chinese state-owned energy firm) have all been dissatisfied with the quality of oil purchased from the U.S. Strategic Petroleum Reserve (SPR). Shell oil trader Steve Sellers wrote that his multinational company was "unpleasantly surprised" to discover high levels of hydrogen sulfide (HS2) in oil purchased from the SPR, the world's largest government reserve.
High H2S incidents are rare in the crude world, but are typically caused by the blending of different crude grades. If one crude grade was placed in a barrel where a different crude grade has resided, contamination becomes a possibility. The Energy Department has declined to comment on the finding.
HS2 is a colorless, flammable, hazardous gas that naturally occurs in petroleum. It is detectable by its rotten egg smell. Decontamination before a sale is standard practice around the world, and not just because of the stink. HS2 can corrode pipelines and has a wide array of negative affects on people depending on levels exposure. According to OSHA, symptoms can range from nausea and loss of sleep to nearly instant death.
Initial tests run by Shell showed up fine, but further testing revealed H2S numbers running up to 600 parts per million (ppm), according to the Dutch-British company's emails to the department. OSHA says that levels that high could reduce a a grown adult to staggering and collapse within 5 minutes.
When a third party inspection group known as Inspectorate tested a sample from the SPR cargo purchased by the Australian Macquarie to be then sold to PetroChina, similar problems occurred. According to the Reuters-obtained documents, H2S levels of up to 9,000 parts per million (ppm) appeared. OSHA's warnings about H2S end at 2,000 ppm, where nearly instant death occurs. A terminal operator refused to allow workers to perform any additional tests out of concern about violating safety regulations.
The U.S SPR contains 665 million barrels of petroleum, stockpiled in case of a national shortage of oil like the one that happened in 1975 after an Arab oil embargo. SPRs are common across the globe, but there hasn't been such a crisis in decades, and some groups have called for the United States to end it completely.
In February of this year, a Congressional spending deal signed by President Trump declared that the United States would sell 100 million barrels of oil from the SPR by 2027. At the time, Kevin Book, managing director of ClearView Energy Partners in Washington told Bloomberg that "this is nothing short of liquidation of a safety net." But contamination in the U.S SPR could throw a wrench into the whole plan.
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