(Beyond Pesticides, March 2, 2021) Populations of solitary ground nesting bees decline after exposure to neonicotinoid insecticides, according to a study published in Scientific Reports late last month. In addition to ground-nesting bees, neonicotinoids have been shown to harm butterflies, hummingbirds, songbirds, aquatic species and mammals, including humans. As independent science continues to look beyond the effects of these systemic chemicals on honey and bumblebees, advocates maintain that it has become increasingly clear that the high hazards presented by neonicotinoids necessitate their complete elimination. “Farmers need to protect their crops from pests, but they also absolutely need to protect pollinators from the unintended effects of pesticides,” said study coauthor Susan Willis Chan, PhD. “The data on this particular [neonicotinoid] product are so clear that there’s really no question about what has to happen. We have to find something else.” Researchers focused their effort investigating how various systemic pesticides effect the hoary squash bee (Eucera pruinosa), a ground nesting bee found throughout North America that feeds entirely on pollen from cucurbits (including squash, cucumber, pumpkin, gourds, etc). The hoary squash bee provides essential pollinator services for these crops throughout the U.S. and Canada. Neonicotinoids and other systemic insecticides are often applied […]

(Beyond Pesticides, February 23, 2021) The same pesticides implicated in the worldwide decline of insect pollinators also present significant risks to their avian counterparts, hummingbirds. Well known for their nectar-fueled hovering flight powered by wings beating over 50 times per second, hummingbirds display unique reactions to toxic pesticides. Research by scientists at the University of Toronto finds that hummingbirds exposed to systemic neonicotinoid insecticides for even a short period of time can disrupt the high-powered metabolism of this important and charismatic animal. Scientists began their experiment by trapping 23 wild ruby-throated hummingbirds and housing them in an animal care facility. One group of birds acted as a control and received no pesticide exposure, while the rest were assigned either low, middle, or high exposure (1 part per million [ppm], 2ppm, and 2.5ppm, respectively) to the neonicotinoid imidacloprid. Scientists determined these amounts based upon probable nectar contamination in the real world. The pesticide was incorporated into the sugar solution provided to the birds over the course of three days. Within two hours of exposure to the pesticides, hummingbird metabolism dropped significantly. While the control group increased energy expenditure between 1% to 7%, the low exposed group displayed a 6% average decline, […]

(Beyond Pesticides, February 22, 2021) Congressional Rep. Joe Neguse, Rep. Alan Lowenthal and Chair of the Natural Resources Subcommittee on Water, Oceans and Wildlife Rep. Jared Huffman have reintroduced their resolution (H.Res. 69: Expressing the need for the Federal Government to establish a national biodiversity strategy for protecting biodiversity for current and future) to create a national biodiversity strategy. Everywhere we turn, we see signs of ecological collapse—wildfires, the insect apocalypse, crashing populations of marine organisms, more and more species at risk, rising global temperatures, unusual weather patterns, horrific storms, and pandemics. Never was a holistic strategy on biodiversity more urgent. Tell your U.S. Representative to cosponsor Rep. Neguse’s National Biodiversity Strategy Resolution, H.Res. 69. The resolution calls for a natio. 69.nal commitment to addressing the biodiversity crisis by establishing a strategy to be developed through an interagency process announced by the president in an Executive Order. The strategy process will encourage agencies to identify and pursue a full range of actions within existing laws and policies and encourage consideration of new ones. It would also promote accountability and progress in addressing the biodiversity crisis through a new quadrennial assessment. “The decline of biodiversity presents a direct threat to the security, […]

(Beyond Pesticides, February 16, 2021) The climate crisis, with unprecedented temperature shifts, storms, and wildfires, and the devastating decline in biodiversity are escalating as a result of uncontrolled and unnecessary reliance on toxic chemicals. These existential crises that threaten life, to be successfully thwarted, require a meaningful holistic strategy that commits our nation to ending our fossil fuel-based economy and use of petroleum-based materials that release harmful levels of carbon and noxious gases (including greenhouse gases/GHG) into the environment. The proposals now in Congress and the administration require close attention and scrutiny if we are to meet the urgency of the moment. The carbon market approach embodied in the Growing Climate Solutions Act and President Biden’s Climate 21 Project does not adequately and comprehensively respond to the current and looming interconnected threats to public health and the environment. The focus on carbon to the exclusion of a holistic approach that addresses complex life-supporting biological communities allows the continuation of disproportionate hazards to people of color and communities living adjacent to toxic sites. The mechanisms of carbon trading or the purchasing of carbon offsets under consideration do not establish an end date for admittedly unacceptable materials and practices, nor do they ensure a […]

(Beyond Pesticides, February 12, 2021) Being many decades down the path of chemical-intensive agriculture, growers and other land managers (and all the industries that influence them) have come largely to ignore the efficacy of healthy, functioning natural systems to maintain ecological equilibrium, i.e., not letting any one pest or disease proliferate. Recent research points to an example of such ecosystem efficacy. The study, by researchers in California and China, sought to evaluate whether increased population densities of fungi might be suppressing nematode populations in California production fields frequently planted with the cole crops (such as brussels sprouts and broccoli) they favor. The research finds that a diverse population of fungi in soils is highly likely to be effectively killing nematodes that threaten such crops. This is not the first time Beyond Pesticides has covered the potential of fungi as an effective control for agricultural pests. Thirty years ago, these nematodes were dealt with by application of soil fumigants and nematicides, because at sufficient population levels, the nematodes can destroy cole crops. During the following three decades, state-mandated monitoring showed that use of those chemical controls was diminishing and, by 2014, had been eliminated — even as yields rose. The co-authors […]

(Beyond Pesticides, February 8, 2021) Immediately following his inauguration, President Biden issued an Executive Order (EO) directing the heads of all executive departments and agencies to produce recommendations for improving and modernizing regulatory review, with a goal of promoting public health and safety, economic growth, social welfare, racial justice, environmental stewardship, human dignity, equity, and the interests of future generations. This Executive Order, if effective, will  reverse the historical trend of status-quo regulatory reviews required by the White House Office of Management and Budget (OMB) that typically support vested economic interests of polluters (e.g., petroleum-based pesticide and fertilizer manufacturers). Instead, the President’s EO, Modernizing Regulatory Review, sets the stage for the adoption of agency policy across government to seriously and with urgency confront the climate crisis, biodiversity collapse, and disproportionate harm to people of color communities (environmental racism). Key agencies that can have a systemic effect in meeting these existential challenges are the Environmental Protection Agency (EPA), Department of Interior (DOI), Department of Agriculture (USDA), and Department of Labor/Occupational Safety and Health Administration (DOL/OSHA). But the EO will remain words on a page unless we all across the country exercise our voice and advocate for the changes necessary to end […]

(Beyond Pesticides, January 28, 2021) Persistent organic pollutants (POPs)—including banned pesticides—present a health risk to the endangered Qinling Panda (Ailuropoda melanoleuca qinlingensis), the rarest subspecies of giant pandas, according to a new Chinese study published in Environmental Pollution. Organochlorine compounds (OCs), such as organochlorine pesticides (OCPs) and polychlorinated biphenyls (PCBs), are well-known persistent organic pollutants. They were banned by the Stockholm Convention treaty in 2001 and are primary pollutants of concern (UNEP, 2009) because of their persistence, toxicity, and adverse effects on environmental and biological health. These pollutants have a global distribution, with evaporation and precipitation facilitating long-range atmospheric transport, deposition, and bioaccumulation of hazardous chemicals in the environment. The U.S. was a signatory to the treaty, but U.S. Senate never ratified it, relegating U.S. officials to observer status. Although various studies demonstrate the volatile, toxic nature of POPs, much less research evaluates the impact POPs have on biodiversity over time. The globe is currently going through the Holocene Extinction, Earth’s 6th mass extinction, with one million species of plants and animals at risk. With the increasing rate of biodiversity loss, advocates say it is essential for government agencies to research how previous and ongoing use of POPs can impact present-day species. Likewise, collaborative, […]

(Beyond Pesticides, January 27, 2021) Lowest ever recorded! That’s the result of a yearly winter monarch count along the California coast, overseen each year by the conservation group Xerces Society. In 2020, citizen scientists counted only 2,000 butterflies. The findings indicate that many on the planet today are likely to experience, within their lifetimes, a world where western monarchs are extinct—unless the federal government acts now. Western monarchs migrate from the Pacific Northwest to overwintering grounds along the California coast, where they remain in relatively stationary clusters that are easy to count.  In the 1980s, roughly 10 million monarchs overwintered along the coast. By the 1990s, that number fell into the low single digits, roughly 1.2 million. Five years ago counts were at roughly 300,000. By 2019, numbers crashed below 30,000. This year’s count saw no monarchs at iconic overwintering sites like Pacific Grove. Other locations, like Pismo State Beach Monarch Butterfly Grove and National Bridges State Park saw only a few hundred. “These sites normally host thousands of butterflies, and their absence this year was heartbreaking for volunteers and visitors flocking to these locales hoping to catch a glimpse of the awe-inspiring clusters of monarch butterflies,” said Sarina Jepsen, […]

(Beyond Pesticides, November 19, 2020) A new study by researchers at the University of California, Santa Barbara (UCSB) finds that crop diversity in commercial agriculture is just as essential to supporting a stable biological system as plant diversity on non-commercial landscapes. Furthermore, less diverse crop areas lead to higher, more intensive pesticide use, indicating a threat to environmental and human health, as well as food security. This research highlights the need to develop policies that facilitate a decrease in overall pesticide use by helping farmers and global leaders make more knowledgeable decisions about crop area size and diversity to sustain biodiversity. Researchers note, “While [crop] complexity increases stability and reduces high deviations in insecticide use, accounting for crop and farmer-specific characteristics is crucial for statistical inference and sound scientific understanding. In this study, researchers aim to understand how crop and landscape diversity impacts pest populations, using insecticide use data as a surrogate for pest populations data. Data observations are from Kern County Agricultural Commissioner (CAC), California, over the period 2005 to 2017. Crop data includes crop type, acceptable field size, field and farmer permit number, and active dates for the field. To estimate pesticide use variance, researchers summated annually and peak insecticide […]

(Beyond Pesticides, November 10, 2020) Higher rates of plant diversity can limit pest pressure and reduce the need for pesticide use, finds a new study published by the German Centre for Integrative Biodiversity Research. With rampant declines in insect biodiversity from the ongoing insect apocalypse, it is critical that farmers and ecologists better understand the natural interplay between plants and insects, and the important ecosystem services that flow from these interactions. “Our experiments show that conserving plant diversity provides multiple benefits for controlling herbivore pests, which could play a key role in reducing inputs of agrochemicals and enhancing plant productivity,” said study coauthor Andrew Barnes, PhD. Scientists investigated the importance of plant biodiversity through study of two ongoing biodiversity experiments. One known as the The Jena Experiment, based in Central Europe, and another, the Cedar Creek Biodiversity Experiment, in the state of Minnesota. Both sites established blocks of plant diversity gradients, flowing from monoculture plots to those with 16 species or more. Researchers aimed to investigate how insect food webs and feeding behavior, plant biomass, and pest predator response changes as a function of plant biodiversity. Results showed that higher plant diversity resulted in an insect (herbivore pest) feeding rate […]

(Beyond Pesticides, October 29, 2020) Natural areas around farmlands play an important role in managing pest outbreaks and therefore reducing insecticide use, a new study published in the journal Ecology Letters finds. While industrial agriculture puts pressure on farmers to grow single crops on ever larger farms to achieve economies of scale, these monoculture landscapes have significant downsides for public health and the environment. “Overall, our results suggest that simplified landscapes increase vineyard pest outbreaks and escalate insecticide spray frequencies,” said lead author Daniel Paredes, PhD, to the Daily Democrat. “In contrast, vineyards surrounded by more productive habitats and more shrubland area are less likely to apply insecticides.” To investigate the effect of nearby landscapes on farm pest pressure, the team of University of California, Davis scientists used a database created by the government of Spain. For 13 years, the government monitored 400 Spanish vineyards for the presence of the European Grapevine Moth. The moth is a notorious vineyard pest (discovered in California vineyards in 2009), laying three generations of eggs on grapes. In the first generation, the moth larvae will web and feed on flowers. In the second and third, they feed on berries, damaging harvests. Scientists developed a […]

(Beyond Pesticides, October 1, 2020) A federal judge on September 24, 2020 dismissed an  environmental lawsuit seeking to reinstate a U.S. Fish and Wildlife Service (FWS) rule, killed by the Trump Administration, which banned the use of neonicotinoid insecticides, genetically engineered (GE) crops, and adopted a precautionary approach to pest management. The decision comes on the heels of a Center for Biological Diversity (CBD) analysis that reports a 34% increase in the pesticide use on U.S. national wildlife refuge acres over a two year period from 2016-2018. This analysis is an update to CBD’s 2018 report, No Refuge, which is the first of its kind to offer comprehensive details of agricultural pesticide spraying in national wildlife refuges. Wildlife refuges act as a sanctuary, providing habitat and protection essential for the survival and recovery of species nationwide. However, pesticide spraying in or around wildlife refuges threatens the survivability and recovery of species that reside there as many of these pesticides are highly toxic to human and animal health. Analyses like these are significant, especially since the globe is currently going through the Holocene Extinction, Earth’s 6th mass extinction, with one million species of plants and animals at risk of extinction. In 2012, […]

(Beyond Pesticides, September 17, 2020) The apparel industry becomes the latest contributor to global biodiversity loss, directly linking soil degradation, natural ecosystems destruction, and environmental pollution with apparel supply chains, according to the report, “Biodiversity: The next frontier in sustainable fashion,” by McKinsey & Company. Although there are many studies on the fashion industry’s impact on climate change, much less research discusses the impact the industry has on biodiversity. The globe is currently going through the Holocene Extinction, Earth’s 6th mass extinction, with one million species of plants and animals at risk of extinction. With the increasing rate of biodiversity loss, advocates say it is essential for government agencies to hold the fashion industry accountable for the direct (i.e., excessive agrochemical use, water consumption) and indirect (i.e., water pollution from run-off) impacts on the environment, not only to protect the well-being of animals, but humans, as well. Researchers in the study note, “We expect biodiversity to become an even greater concern for consumers and investors in the coming years. Covid-19, instead of slowing the trend, has accelerated it—perhaps because people now understand more deeply that human and animal ecosystems are interdependent. It’s time for the apparel industry, which to date has contributed heavily […]

(Beyond Pesticides, July 16, 2020) Long-term exposure to sublethal (low-level) concentrations of the neonicotinoid in soil negatively affects the health and behavioral development of black garden ants (Lasius niger) colonies, according to a study published in Communications Biology by scientists at the University of Bern, Switzerland. Ants are one of the most biologically significant insects in the soil ecosystem, acting as ecosystem engineers. Their burrowing behavior aerates the soil, allowing oxygen and water to penetrate down to plant roots. Additionally, ants increase soil nutrient levels by importing and accumulating organic material like food and feces, thus enhancing nutrient cycling. Like many other insects, ants are unfortunate victims of the global insect apocalypse or population decline, and much research attributes the recent decline to several, including pesticide exposure. Broad-spectrum pesticides, like neonicotinoids, indiscriminately kill pests and nontarget organisms alike, as their ubiquitous use contaminates soils, even in untreated areas. This study highlights the necessity of rethinking chemical pest management, developing sustainable agricultural practices that reduce the use of agrochemicals, like pesticides, to prevent permanent environmental ecosystem damage. Researchers in the study note, “To prevent irreparable damages to functioning ecosystems, [we] suggest to either fully incorporate long-term effects in risk assessment schemes, or to make a shift […]

(Beyond Pesticides, May 26, 2020) Across the pond, the European Commission (EC) has announced plans to protect biodiversity and build a more sustainable food system, and identified the reduction of pesticide use  and the expansion of organic agriculture as pillars of the scheme. The EC expects that the initiative, which will require EU member states’ endorsement, will advance progress on the EU goal of eliminating greenhouse gas emissions by 2050, given that 10% of emissions arise from the agricultural sector. The EC’s goals are important and laudable, but Beyond Pesticides is clear: reduction of pesticide use in service of them is not an adequate strategy to ensure long-term success. Genuine success requires the elimination of the use of synthetic chemical pesticides, fertilizers, and other toxic inputs, and the transition to agricultural and land management systems that work with nature, rather than fight against it. Regenerative, organic practices are the path to a livable future, according to Beyond Pesticides. The EC, which is the executive branch of the EU, expects its plan to reduce use of pesticides by 50% by 2030; reduce use of antimicrobial chemicals, including antibiotics, in fish and animal farming by 50%; dedicate a minimum of 25% of arable […]

(Beyond Pesticides, May 18, 2020) On May 15, 2020, Beyond Pesticides sued Exxon Mobil Corporation (Exxon) for “false and deceptive marketing,” misrepresenting to consumers that it “has invested significantly in the production and use of “clean” energy and environmentally beneficial technology.” The truth, according to the complaint (Beyond Pesticides v. Exxon Mobil Corporation) filed in DC Superior Court, is that the vast majority of Exxon’s business continues to be in the production and use of petroleum, natural gas, and petrochemicals, including pesticides. These activities are significant contributors to the climate crisis and the decline of pollinators and biodiversity, threatening the viability of biological systems that sustain life, according to Beyond Pesticides. “ExxonMobil’s advertising and marketing mislead the public by presenting ExxonMobil’s clean energy activities as a significant proportion of its overall business,” according the lawsuit. In an age where consumers are looking to support responsible companies that are supporting and transitioning away from fossil fuel-based energy and chemical products, “ExxonMobil is able to capture the growing market of consumers,” according to the complaint. Surveys have found that consumers are more likely to buy products and services based on corporate image. For example, a 2015 Nielsen survey finds that the majority […]

(Beyond Pesticides, April 29, 2020) The terrible reputation with which bats are commonly saddled — especially now, because of their association with the origins of the family of coronaviruses — is undeserved. These nocturnal insect vacuums are fascinating, flying mammals that are under-appreciated, not least for their performance of important services for ecosystems, and for human health and agriculture. Investigators from Israel’s Ben-Gurion University and the Section for Evolutionary Genomics at Copenhagen’s Natural History Museum recently published a study demonstrating that bats can be a mighty tool against pests that damage cotton crops. Bats’ pest control services — relatively invisible because they do their insect marauding at night when humans are not watching — represent an excellent, nontoxic, biological control for some agricultural pests, as well as for mosquitoes that may be human disease vectors. Advocates say that these services should be well considered before any decision to use toxic pesticides that can harm bats, as Beyond Pesticides has covered. The study, “An appetite for pests: Synanthropic insectivorous bats exploit cotton pest irruptions and consume various deleterious arthropods,” was published in Molecular Ecology. [Note: “synanthropic” species are those plants or animals that live near, and benefit from, association with humans […]

(Beyond Pesticides, April 28, 2020) Roughly a quarter of the global insect population has been wiped out since 1990, according to new research published in the journal Science. Billed as one of the most comprehensive assessments to date, the study finds significant overall insect declines, but notes of some specific bright spots. While variation in the ongoing crisis is to be expected, ultimately the trends in the data show the need for immediate policy and regulatory action to protect the insect world as the foundation of global food webs. The team of European scientists behind the research analyzed 166 studies spread out over 41 countries, and consisting of over 1,600 sites, with data beginning in the mid-1920s. Overall trends found declines in terrestrial insect biomass to be nearly 1% each year (~9% each decade). However, contrasting this data was a bright spot – freshwater insects were found to be increasing at an annual rate just over 1% (~11% each decade). The authors caution, however, that because fresh water covers only 2.4% of the earth’s surface, the increase may not be a good spatial representative of broader trends. While North America appeared to show more significant declines when compared to Europe, […]

(Beyond Pesticides, March 17, 2020) The number of monarch butterflies overwintering in Mexico is down 53% from last year, according to a count conducted by World Wildlife Fund (WWF) Mexico. While WWF indicates the decline was expected due to unfavorable weather conditions during the species southward migration, other environmental groups are raising red flags. “Scientists were expecting the count to be down slightly, but this level of decrease is heartbreaking,” said Tierra Curry, a senior scientist at the Center for Biological Diversity. “Monarchs unite us, and more protections are clearly needed for these migratory wonders and their habitat.” WWF’s count found that monarchs occupied seven acres this winter, down from 15 acres last year. Reports indicate that 15 acres is a minimum threshold needed to prevent a collapse of the butterfly’s migration and possible extinction. This was the goal stated by the 2015 White House Pollinator Task Force, which the current administration is failing to see through. While weather conditions play an important role in monarch migration from the U.S. and Canada south to Mexico, the species is under threat from a range of environmental factors. Monarchs depend on milkweed plants to lay eggs, and monarch caterpillars feed solely on […]

(Beyond Pesticides, March 9, 2020) It’s time to think about gardening! Whether you’re growing vegetables to eat or flowers for pollinators, you’ll want to be sure that your seeds and plants are free from harmful pesticides. Seeds and plants in many garden centers across the country are grown from seeds coated with toxic fungicides and bee-harming neonicotinoid pesticides, or drenched with them. Plant organic seeds and plants! As bees suffer serious declines in their populations, we urge people and communities to plant habitat that supports pollinator populations, and have provided information to facilitate this in our BEE Protective Habitat Guide. However, plants are too often grown with hazardous pesticides that either harm pollinators in their cultivation or threaten bees as they pollinate or forage on treated plants. For more information on the dangers of neonicotinoid coated seeds, see Beyond Pesticides’ short video Seeds That Poison. Beyond Pesticides has compiled a directory of companies and organizations that sell organic seeds and plants to the general public. Included in this directory are seeds for vegetables, flowers, and herbs, as well as living plants and seedlings. Specific questions on each seller’s seeds can be directed to their customer service line. You can also download a handy bi-fold brochure version of this […]

(Beyond Pesticides, March 6, 2020) Scientists from Imperial College London have just published their recent research on impacts of pesticides on larval bumblebees exposed through neonicotinoid-contaminated food sources. Many studies have looked at the devastating impacts of pesticides on adult insects, including pollinators — and bees, in particular. This research, however, examines how exposure to the neonicotinoid imidacloprid, through consumption of contaminated nectar and pollen during the larval stage, affects bumblebees (Bombus terrestris audax). It finds that these exposures cause abnormal brain growth in some parts of the bees’ brains, and significantly impairs learning ability compared to bees who were not exposed. Advocates maintain that neonicotinoid pesticides should be banned for their widespread and severe damage to insects and the environment broadly, in addition to human health concerns. Neonicotinoids (neonics) comprise a class of pesticide used intensively in many parts of the world. They may be applied to plant foliage, or directly to soils as a drench, but the predominant use is for seed treatment. These pesticides are banned or restricted in some places, including in the European Union, France, Germany, and Italy; some states have also worked to rein in their use. Previous research out of Harvard University has […]

Experimental ponds in Gault Nature Reserve. Photo credit: Vincent Fugère (Beyond Pesticides, March 5, 2020) A new study conducted by researchers at McGill University investigated phytoplankton (microscopic algae) response and resilience to Roundup exposure. “Community rescue in experimental phytoplankton communities facing severe herbicide pollution” was published in Nature Ecology & Evolution. Researchers found that algae can develop resistance to contamination, but surviving phytoplankton communities are much less diverse. Diversity loss is cause for concern as it could hinder adaptation to other potential stressors, such as climate change.  Using experimental ponds, researchers first exposed some phytoplankton communities to low levels of Roundup over time, then dosed the ponds with a lethal amount.  Groups that had been given low doses survived the lethal phase whereas unpolluted, control ponds did not. Researchers observed “community rescue,” where genetic changes avert population collapse in a lethal environment. In fact, glyphosate eventually became a fertilizer in resistant ponds as it is a significant source of phosphorus. Other studies, too, have noted that phosphorous loading is an overlooked impact of glyphosate contamination. Phytoplankton matter because their disruption can cause a trophic cascade and impact other organisms. “These tiny species at the bottom of the food chain play […]

(Beyond Pesticides, February 21, 2020) Last week in Minnesota, state Representative Jean Wagenius introduced measure H.F. 1255 that would give cities the opportunity to ban local use of bee-lethal pesticides. This is the latest in a series of attempts to fight state pesticide preemption, an industry-promoted law that prevents localities from restricting pesticide use more stringently than the state. In the face of inaction at the federal and state levels, advocates and legislators in Minnesota are attempting to regain local control to help save their declining, Midwestern pollinators. Representative Wagenius says about the measure, “Minnesotans should be able to protect pollinators if they want to. We value local control in this state, and we always have.” H.F. 1255 will allow cities to opt into a blanket ban of pesticides determined by the Environmental Protection Agency (EPA) to be hazardous to bees. Pesticides with an EPA bee-advisory box are listed on the state’s Department of Agriculture website and referred to as “bee-lethal” by Minnesota legislators. Patrick Hanlon, director of environmental programs for the city of Minneapolis, says cities would work with Department of Agriculture, businesses, and residents that might be impacted by these restrictions before enacting the bill. Local advocates have […]