the pretense of scientific research to evade its commitments to the world community". The Australian delegation to the IWC has argued to repeal the provision that allows nations to harvest whales for scientific research, to no effect. Japan, meanwhile, lodged a formal objection to the sanctuary with regard to minke whales, meaning that the terms of the sanctuary do not apply to its harvest of that species within the boundaries of the sanctuary. Claiming the Japanese whaling fleet's actions to be illegal, the Sea Shepherd Conservation Society acts against Japanese whaling ships engaged in yearly hunts, attempting to interrupt or cut short the whaling activities. The ICR considers the activists' methods as constituting piracy, terrorism, and illegal harassment of the ICR fleet. Critics of the ICR point out that recent scientific advances allow for the use of non-lethal techniques in cetacean research, such as biopsies or determination of cetacean dietary intake through analysis of DNA samples from whale feces. During the 2010/2011 whaling season, the ICR was forced to halt its whaling operations due to the actions of the Sea Shepherd Conservation Society, having harvested 172 whales (a fifth of their season quota). The ICR dispatched its whaling fleet as usual to the Northwest Pacific survey (JARPN II), with a quota for 260 whales, including 100 Minkes. Dispute over legality Japan has argued that the establishment of the Southern Ocean Whale Sanctuary was in contravention of the International Convention for the Regulation of Whaling (ICRW) on which the IWC is based and is therefore illegal. This view received strong support from Professor W. T. Burke of the University of Washington in his paper circulated as IWC Document Number IWC/48/33. He refers to Article V(2) of the ICRW, which states that the creation of any sanctuary must "be based on scientific findings" and "take into consideration the interests of the consumers of whale products and the whaling industry". Prof Burke's interpretation is disputed by Prof Chris Wold of the Northwestern School of Law of Lewis & Clark College, who argued that the IWC must maintain both the conservation and whaling industry objectives of the ICRW. This view is supported by Alexander Gillespie, Professor of Law at the University of Waikato, who reasoned in his 2006 book, Whaling Diplomacy, that phrases such as "best interests of the whaling industry" must now consider commercial non-consumptive use (such as whale watching). As there is