(Beyond Pesticides, August 13, 2009) The Alaska Department of Environmental Conservation is currently reviewing a request by the Alaska Railroad for permission to use the herbicide glyphosate along a 90 mile stretch of its track between Seward and Indian. The herbicide is set to be applied on Railroad operating property (rail yards, spurs, sidings, etc) and along the mainline and branch line right-of way for four feet out from both sides of the track in the summer of 2010. Despite the fact that previous requests have been met with opposition, the railroad states that its vegetation problem has gotten too out of hand for “so-called ”˜alternative methods.’” They also state that the Federal Railroad Administration, the railroad’s federal regulatory agency, will impose fines and operational restrictions such as reducing speeds or emergency closures of some sections of track if they aren’t cleared of the overgrown vegetation. Current methods of weed management utilized by the railroad are mechanized rail-based brushcutters, off-rail hydroaxing, wayside manual cutting. The extents to which these methods are used are unknown, however, and the railroad states that these are effective””but only within limited ranges. Beyond Pesticides has an entire factsheet on least toxic control of weeds which […]

(Beyond Pesticides, July 10, 2009) The Center for Biological Diversity notified the U.S. Environmental Protection Agency (EPA) earlier this week of its intent to file suit against the agency for failing to consider impacts to the polar bear and its Arctic habitat from toxic contamination resulting from pesticide use in the U.S. Pesticides registered by EPA for use in the U.S. are known to be transported to the Arctic via various atmospheric, oceanic, and biotic pathways. Such pesticides are biomagnified with each step higher in the food web, reaching some of their greatest concentrations in polar bears, the apex predators of the Arctic. A body of literature demonstrates the far-reaching effects of commonly used pesticides that are suspected endocrine disruptors and persistent organic pollutants, such as atrazine, 2,4-D, lindane, endosulfan, and permethrin, on global ecosystems. These pesticides, among others, and related contaminants have been linked to suppressed immune function, endocrine disruption, abnormalities in reproductive organs, hermaphroditism, and increased cub mortality in polar bears. Human subsistence hunters in the Arctic, who share the top spot on the food web with the polar bear, also face increased risks from exposure to these contaminants. “The poisoning of the Arctic is a silent crisis […]

(Beyond Pesticides, July 6, 2009) Last week, the U.S. Environmental Protection Agency (EPA) proposed to formally evaluate the harmful effects of 74 pesticides on 11 endangered and threatened species in the San Francisco Bay Area over the next five years, and to impose interim restrictions on use of these pesticides in and adjacent to endangered species habitats. The proposal stems from a settlement agreement with the Center for Biological Diversity, which sued EPA in 2007 for violating the Endangered Species Act by registering and allowing the use of toxic pesticides in Bay Area endangered species habitats without determining whether the chemicals jeopardize those species’ existence. “Tens of millions of pounds of toxic and poisonous chemicals, known to be deadly to endangered species and harmful to human health, including proven carcinogens and endocrine disruptors, are applied in the Bay Area each year, and many of those find their way through runoff or drift into our soil, creeks and rivers, San Francisco Bay, and sensitive wildlife habitats,” said Jeff Miller, conservation advocate with the Center. “The toxic stew of pesticides in the Bay-Delta has played a major role in the collapse of native fish populations, and pesticides are a leading cause of […]

(Beyond Pesticides, June 29, 2009) Last week the United States Court of Appeals for the Ninth Circuit re-affirmed its previous decision upholding a nationwide ban on the planting of genetically-engineered (GE) Roundup Ready alfalfa pending a full Environmental Impact Statement (EIS). The Court determined that the planting of genetically modified alfalfa can result in potentially irreversible harm to organic and conventional varieties of crops, damage to the environment, and economic harm to farmers. Although the suit was brought against the United States Department of Agriculture (USDA), Monsanto Company and Forage Genetics entered into the suit as Defendant-Intervenors. In September 2008 the Ninth Circuit affirmed the lower court’s ruling, but the Intervenors continued to press the appeal alone, requesting the appellate court to rehear the case. Last weeks decision denied that request and re-affirmed the earlier decision in full. “This ruling affirms a major victory for consumers, ranchers, organic farmers, and most conventional farmers across the country,” said Andrew Kimbrell, Executive Director of the Center for Food Safety. “Roundup Ready Alfalfa represents a very real threat to farmers’ livelihoods and the environment; the court rightly dismissed Monsanto’s claims that their bottom line should come before the rights of the public and […]

(Beyond Pesticides, April 13, 2009) Rebuffing the Department of Agriculture, the Justice Department announced that it will not seek rehearing of a recent significant environmental decision that enables improved protection from pesticides under the Clean Water Act. In a letter dated March 6, 2009, Agriculture Secretary Vilsack had asked EPA Administrator Jackson to request reversal of the 6th Circuit’s decision (The National Cotton Council et al. v. EPA) in January that invalidated a Bush EPA rule exempting pesticide spraying around waterways from the Clean Water Act regulations. “This decision means that EPA recognizes its responsibility to move forward with implementing the Clean Water Act, instead of trying to circumvent this bedrock public protection statute as was attempted by the Bush EPA,” stated Charlie Tebbutt of the Western Environmental Law Center, who argued the case for the environmental plaintiffs. “We now look forward to working with EPA and the states to bring about meaningful changes in site specific uses of pesticides to protect our nation’s waters,” continued Mr. Tebbutt. In this same announcement, EPA stated that it will seek to continue the Bush rule for two years, despite the court ruling it illegal. “This part of the EPA’s decision is troubling,” […]

(Beyond Pesticides, March 27, 2009) A federal court has ordered the U.S. Fish & Wildlife Service to stop planting genetically engineered (GE) crops on its Prime Hook National Wildlife Refuge in Delaware. While the ruling is limited to Prime Hook, the lawsuit may serve as a model for similar litigation at more than 80 other national wildlife refuges now growing GE crops across the country. Filed in April 2006 by the Widener Environmental and Natural Resources Law Clinic on behalf of Delaware Audubon Society, Public Employees for Environmental Responsibility (PEER) and the Center for Food Safety, the federal suit charges that the Fish and Wildlife Service (FWS) illegally entered into Cooperative Farming Agreements with private parties, allowing hundreds of acres to be plowed over without required environmental review and contrary to FWS’ own policy prohibiting GE crops. “It is unfortunate that we had to file suit against the Service to get it to comply with its own policies,” commented Nicholas DiPasquale, Conservation Chair for Delaware Audubon. “It is clear that this Refuge Manager had abdicated control over farming operations at Prime Hook just as it is also clear that farming practices have been extremely destructive to the forested uplands at […]

(Beyond Pesticides, February 25, 2009) After three years of legal battle, the North Carolina Pesticide Board on February 19, 2009 fined Florida-based Ag-Mart Produce Inc. a substantially lower fine of $3,000 than the originally proposed $185,000, after deciding that it can only prove six of about 200 worker safety accusations that had been levied against the company. This comes less than a month after the unprecedented ruling against Ag-Mart in New Jersey, where the company was ordered to pay penalties of more than $931,000 for misusing pesticides and jeopardizing the health and safety of workers in its New Jersey farm fields and packing houses. The Florida-based company, described as one of the biggest pesticide offenders, has been accused of routinely exposing hundreds of workers to toxic chemicals. Investigators in North Carolina, Florida and New Jersey, the three states where the international company grows its tomatoes, scrutinized the company’s records and charged it with ignoring laws intended to keep workers safe from toxic pesticide residue. The investigators alleged workers were sent into the fields too soon after dangerous chemicals had been sprayed. The case started three years ago when some workers gave birth to babies with severe birth defects. One mother […]

(Beyond Pesticides, December 22, 2008) The U.S. EPA has filed an administrative complaint, seeking a maximum penalty of only $4,550, against a pest control company that sprayed pesticides in a couple’s home, causing the wife to die shortly thereafter. It has been more than three years since the incident took place in Florence, Oregon. Swanson’s Pest Management of Eugene, Oregon sent an employee to a home on June 29, 2005 to apply Conquer Residential Insecticide Concentrate, active ingredient esfenvalerate, and ULD BP-100 Contact Insecticide, active ingredient pyrethrin. The couple returned to their home two and a half hours later and immediately fell to the ground due to the fumes. Paramedics were called in and they too experienced respiratory distress or became ill when they entered the treated home. According to The Oregonian, Florence Kolbeck was 76 years old and died of cardiac arrest as a result of the exposure. Her husband, Fred, was hospitalized for respiratory distress. The complaint was filed following a review of Swanson’s use of the two pesticides, finding that the company failed to properly ventilate the home prior to the occupants re-entering, and improperly applied Conquer as a “space spray” at nearly three times the allowable […]

(Beyond Pesticides, November 26, 2008) On November 10, two Alaskan environmental groups sued the United States Fish and Wildlife Service (FWS) for failing to conduct a proper assessment of the environmental consequences of using herbicides to kill non-native species in Kodiak National Wildlife Refuge and the Alaska Maritime National Wildlife Refuge. The groups, Alaska Survival and Alaska Community Action on Toxics, allege that FWS sprayed hundreds of gallons of herbicide in the Kodiak National Wildlife Refuge and the Alaska Maritime National Wildlife Refuge over the past several years. In the complaint to the U.S. District Court of Alaska, the groups say FWS violated the National Environmental Policy Act (NEPA) by failing to conduct adequate investigations on the environmental impacts of pesticide use and by failing to inform the public of the practice. The lawsuit states, “(Fish and Wildlife) failed to consider the potential harm to aquatic organisms, fish, birds, insects and other non-target species, as well as the potential for adverse effects to humans visiting the area,” and that the “defendants failed to consider the effect of herbicide use on the commercial salmon fishing industry and on subsistence users.” Under NEPA, all federal agencies are required to conduct an Environmental […]

(Beyond Pesticides, November 19, 2008) In what is described as a great victory for environmental campaigner Georgina Downs, a British high court ruled last week that there was “solid evidence” that rural residents had suffered harm from crop spraying with toxic chemicals. The landmark ruling ordered the Government to reconsider how to protect the health of countryside communities. This victory comes after a long-running legal battle over the use of pesticides in rural communities. Ms. Downs, who lives on the edge of farmland, launched her campaign in 2001 and documented that she was first exposed to pesticide spraying in the early 1980s at the age of 11 and has since suffered from ill health, flu-like symptoms, sore throat, blistering and other problems. She created a DVD portraying collected evidence from other rural residents reporting health problems including cancer, Parkinson’s disease and asthma believed to be linked to crop spraying. Ms. Downs said the government had failed to address the concerns of people living in the countryside. She added that these people “are repeatedly exposed to mixtures of pesticides and other chemicals throughout every year, and in many cases, like mine, for decades.” She also noted that people were not given […]

(Beyond Pesticides, October 1, 2008) Last week, a jury awarded $1 million in compensation to an organic farm in Santa Cruz, California, whose herbs were contaminated by pesticides. The jury found that organophosphate pesticides, used on vegetables on neighboring farms, drifted onto the organic farm, leaving the herbs in violation of organic standards. The organic farm, Jacobs Farm Del Cabo, filed a lawsuit against the pesticide application company Western Farm Service, Inc. in May 2007. The suit sought an order to stop Western Farm Service from spraying pesticides that contaminate crops at Wilder Ranch State Park, where Jacobs Farm leases 120 acres. Compensation for losses, in the sum of $1 million, which resulted from pesticide contamination, was also sought. The court ruled that pesticide applications by Western Farm Service resulted in trespass of the pesticides onto Jacobs Farm and were legally determined to be a nuisance depriving Jacobs Farm of the right to use and enjoy the land, caused by negligence on the part of Western Farm Services. The jury found that Jacobs Farm was damaged in the sum of $1 million and Judge Robert Atack ordered judgment in that amount against Western Farm Service. The organophosphates, chlorpyrifos, diazinon, and […]

(Beyond Pesticides, September 26, 2008) On September 24, the U.S. Ninth Circuit Court of Appeals dismissed Ivory Coast farmworkers’ claims that they were victims of genocide when pesticide exposure made them sterile. The nearly 700 plaintiffs were exposed to the soil fumigant and nematocide 1,2-Dibromo-3-Chloropropane, or DBCP, while working on Dole Food Company farms in Africa. The original First Amended Complaint was filed on April 6, 2007, and despite the latest setback, the Africans’ attorney, Raphael Metzger, said he would pursue a rehearing. Until 1977, DBCP was widely used in U.S. agriculture, when it was banned for all uses except pineapples. In contrast, DBCP was widely used for fruit production in developing countries in to the 1990s in spite of its U.S. regulatory status. “The manufacturers continued making money on [DBCP] by shipping it to Third World countries where farmworkers were given it to use,” Mr. Metzger said. The suit, Abagninin v. Amvac Chemical Co, was filed under the Alien Torts Statute and contended “that such conduct supports claims under the ATS for genocide and crimes against humanity because the conduct was undertaken with knowledge of DBCP’s effects and pursuant to a State or organizational policy.” The court rejected Abagninin’s […]

(Beyond Pesticides, September 15, 2008) One year after the USDA’s new regulation requiring raw almonds be treated with propylene oxide, a toxic fumigant recognized as a carcinogen by the U.S. EPA, went into effect, a group of fifteen American almond growers and wholesale nut handlers filed a lawsuit in the Washington, D.C. federal court on September 9th seeking to repeal the controversial USDA-mandated treatment program for California-grown raw almonds. The almond farmers and handlers contend that their businesses have been seriously damaged and their futures jeopardized by the requirement that raw almonds be treated with propylene oxide or steam-heated before they can be sold to American consumers. Foreign-grown almonds are exempt from treatment. They hope for a favorable decision in time to protect this year’s almond harvest. “The USDA’s raw almond treatment mandate has been economically devastating to many family-scale and organic almond farmers in California,” said Will Fantle, the research director for the Wisconsin-based Cornucopia Institute. Cornucopia has been working with almond farmers and handlers to address the negative impacts of the USDA rule, including the loss of markets to foreign nuts. They also contend that the USDA requirement lacks scientific justification, does not address the unsustainable methods used […]

(Beyond Pesticides, September 11, 2008) The North Carolina Pesticide Board has begun hearing evidence in a case from 2004 over suspected pesticide violations that were investigated after three female Ag-Mart farmworkers gave birth to babies with severe birth defects. In 2006, the family of Carlos Herrera Candelario, who was born without arms or legs, sued Ag-Mart over illegal pesticide exposure resulting in the boy’s birth defects. The case was settled out of court, with Ag-Mart agreeing to pay the medical expenses of the boy for life and provide him with a permanent income, but insisting that the settlement was not an admission of guilt. The current hearing will look at whether Ag-Mart’s farm manager, Jeff Oxley, is indeed guilty of over 200 violations, including forcing workers into the field too soon after dangerous pesticides were applied. The hearing is significant because the company insists that adequate practices are and have been in place to ensure workers are not exposed to pesticides, even though the testimony of Ag-Mart employees runs counter to this claim. This hearing could do a great deal to elucidate the truth about farmworker pesticide exposure, an important issue for the thousands of workers who plant and harvest […]

(Beyond Pesticides, September 4, 2008) On September 2, 2008, the U.S. Court of Appeals for the Ninth Circuit upheld a nationwide ban on the planting of genetically-engineered (GE) Roundup Ready alfalfa pending a full Environmental Impact Statement (EIS). The Court determined that the planting of genetically modified alfalfa can result in potentially irreversible harm to organic and conventional varieties of crops, damage to the environment, and economic harm to farmers. Beyond Pesticides is a co-plaintiff in the lawsuit. Although the suit (Geertson Seed Farms, et al. v. Johanns) was brought against U.S. Department of Agriculture (USDA), Forage Genetics and Monsanto entered into the suit as Defendant-Intervenors. In her opinion, Circuit Judge Mary M. Schroeder held that, “Monsanto and Forage Genetics contend that the District Court disregarded their financial losses, but the district court considered those economic losses and simply concluded that the harm to growers and consumers who wanted non-genetically engineered alfalfa outweighed the financial hardships to Monsanto and Forage Genetics and their growers.” “This ruling affirms a major victory for consumers, ranchers, organic farmers, and most conventional farmers across the country,” said Andrew Kimbrell, executive director of the Center for Food Safety, lead plaintiff and counsel in the lawsuit. […]

(Beyond Pesticides, August 28, 2008) The German Coalition Against Bayer Dangers has filed legal action in Germany against Bayer for its role in marketing insecticides that the coalition believes company officials knew were toxic to honey bees. The suit follows recent action by the Natural Resources Defense Council (NRDC) against the Environmental Protection Agency (EPA) to force the agency into compliance with its Freedom of Information Act request for scientific studies relating to clothianidin, one of the Bayer-manufactured pesticides tied to bee toxicity. In May, Germany suspended the approval of eight pesticides linked to a massive bee die-off. Six of the eight suspended are manufactured by Bayer, the other two by Syngenta. Two of the primary active ingredients of concern are clothianidin and imidacloprid, both in the neonicotinoid family of chemicals. They are systemic pesticides, meaning the chemical is incorporated into plant tissue and can therefore be present in pollen and nectar, which is of particular importance to bees. They also have long persistence in the soil and can be absorbed by multiple generations of crops, increasing the likelihood of exposure for bees. Attorney Harro Schultze, who represents the Coalition Against Bayer Dangers said, “The public prosecutor [in Germany] needs […]

(Beyond Pesticides, August 20, 2008) The Natural Resources Defense Council (NRDC) filed a lawsuit on Monday to uncover critical information that the U.S. government is withholding about the risks posed by pesticides to honey bees. NRDC legal experts and a leading bee researcher are convinced that the U.S. Environmental Protection Agency (EPA) has evidence of connections between pesticides and the mysterious honey bee die-offs reported across the country. The phenomenon has come to be called “colony collapse disorder,” or CCD, and it is already proving to have disastrous consequences for American agriculture and the $15 billion worth of crops pollinated by bees every year. EPA has failed to respond to NRDC’s Freedom of Information Act request for agency records concerning the toxicity of pesticides to bees, forcing the legal action. “Recently approved pesticides have been implicated in massive bee die-offs and are the focus of increasing scientific scrutiny,” said NRDC Senior Attorney Aaron Colangelo. “EPA should be evaluating the risks to bees before approving new pesticides, but now refuses to tell the public what it knows. Pesticide restrictions might be at the heart of the solution to this growing crisis, so why hide the information they should be using to […]

(Beyond Pesticides, August 14, 2008) The first report released by the National Marine Fisheries Service (NMFS) as a result of a lawsuit (NCAP et al. v. NMFS, No. 07-1791 RSL) settlement reveal “overwhelming evidence” to suggest that the pesticides chlorpyrifos, malathion, and diazinon increase the chance of extinction for protected salmon and steelhead. The report on the three pesticides and their effects on threatened fish is the first in what is expected to be a four year review process of 37 pesticides. “These are pesticides that EPA [the Environmental Protection Agency] has swept under the rug for years. These are three that stood out as the nastiest of the (pesticides) that are still in widespread use,” said Joshua Osborne-Klein, an attorney for Earthjustice who represented the plaintiff, Northwest Coalition for Alternatives to Pesticides (NCAP). The 377-page report is clear in its conclusion that current use patterns of these three toxic pesticides threaten the salmon and steelhead protected by the Endangered Species Act, but it does not delineate the next steps to reduce the risk. A report on mitigation measures, which could include restrictions or bans, is expected in the next few months. The timing of the report coincides with other […]

(Beyond Pesticides, August 6, 2008) On July 30, 2008, a coalition of fishing and environmental groups settled a lawsuit (NCAP et al. v. NMFS, No. 07-1791 RSL) that requires an impact analysis of 37 pesticides on protected salmon and steelhead in the Pacific Northwest and California. The National Marine Fisheries Service (NMFS), the federal agency charged with protecting threatened and endangered salmon and steelhead, agreed to the settlement, which requires the design and adoption of permanent measures to help pesticide users minimize the harmful effects of those pesticides. The lawsuit, filed last year in the U.S. District Court in Seattle, petitioned the court to order the NMFS to uphold a five-year-old rule that directs the agency to identify measures needed to protect salmon from the pesticides. The petitioners pointed out that NMFS failed to carry out these measures. (See Daily News Blog of November 7, 2007.) The Environmental Protection Agency (EPA) determined that the 37 toxic pesticides at issue in the settlement may harm protected salmon and steelhead. Most of the pesticides have been detected in major salmon and steelhead rivers in the Pacific Northwest and California. Scientists have found that, even at low levels, toxic pesticides can harm salmon […]

(Beyond Pesticides, July 29, 2008) On July 28, 2008, a coalition of farmworker, public health, and environmental groups -including Beyond Pesticides- filed a lawsuit challenging the Environmental Protection Agency’s (EPA) decision to allow continued use of the toxic pesticide diazinon. “The lack of action on diazinon is yet another example of EPA’s failure to fully consider the risks to farmworkers, children, and the environment from pesticides,” said Jay Feldman, executive director of Beyond Pesticides. The lawsuit is part of the coalition’s multi-year campaign to protect children, farmworkers, and wildlife from the most dangerous pesticides and to reform EPA’s lackadaisical regulation of public and environmental health. The coalition has filed a series of lawsuits targeted at the worst poisons on the market: diazinon is near the top of that list. “EPA’s system for protecting the public from the dangers of pesticides like diazinon is broken,” said Joshua Osborne-Klein, an attorney for Earthjustice, the public interest law firm that represents the coalition. “The agency should be protecting farmworkers and children, not the profits of pesticide manufacturers.” Diazinon is an organophosphate pesticide that originates from nerve gases the Nazis developed during World War II. Farmworkers who are exposed to diazinon can suffer muscle […]

(Beyond Pesticides, July 25, 2008) San Francisco, California —  On July 24, 2008,  a broad coalition of farmworker, public health, and environmental groups filed a lawsuit against the Environmental Protection Agency (EPA) to stop the continued use of a hazardous pesticide called endosulfan. The coalition is demanding action from EPA to protect children, farmworkers, and endangered species. Endosulfan is an organochlorine, part of the same family of chemicals as DDT, which EPA banned in 1972. Like other organochlorine pesticides, endosulfan is persistent in the environment and poisons humans and wildlife both in agricultural areas and in regions far from where it was applied. “This dangerous and antiquated pesticide should have been off the market years ago,” said Karl Tupper, a staff scientist with Pesticide Action Network. “The fact that EPA is still allowing the use of a chemical this harmful shows just how broken our regulatory system is.” Acute poisoning from endosulfan can cause headaches, nausea, vomiting, convulsions, and in extreme cases, unconsciousness and even death. Studies have linked endosulfan to smaller testicles, lower sperm production, and an increase in the risk of miscarriages. One glaring omission in the EPA’s decision is its failure to consider risks to children. A […]

(Beyond Pesticides, July 11, 2008) According to an internal Environmental Protection Agency (EPA) memorandum, a Supreme Court decision is undermining the agency’s ability to enforce the Clean Water Act (CWA). Two House Committee Chairmen have sent a letter to EPA Administrator Stephen L. Johnson for more information regarding EPA’s enforcement efforts in the wake of the 2006 decision Rapanos et ux., et al. v. United States. The Rapanos decision was split 4-1-4 over the question of Federal protections for waters of the United States, including wetlands, under the Clean Water Act. In the letter, Chairman James L. Oberstar of the Committee on Transportation and Infrastructure and Chairman Henry A. Waxman of the Committee on Oversight and Reform, explain that information has come to them indicating that enforcement of key clean water programs is faltering. The memo, obtained by Greenpeace and released by the Congressmen, was sent by EPA Assistant Administrator for Enforcement and Compliance Assurance Granta Y. Nakayama and cites enforcement problems created by the Rapanos case and the subsequent guidance. In the memorandum, Mr. Nakayama states, “Data collected from the regions shows that a significant portion of the CWA docket has been adversely affected.” The letter from Congressmen Waxman […]

(Beyond Pesticides, April 7, 2008) A coalition of farmworker advocates and environmental groups filed a lawsuit against the Environmental Protection Agency (EPA) to stop the continued use of four deadly organophosphate pesticides. These pesticides were derived from nerve gas developed during World War II. Some of these pesticides have been detected in California’s rural schoolyards and homes, Sequoia National Park, and Monterey Bay. The four organophosphates at issue in the case filed April 4 are methidathion, oxydemeton-methyl, methamidophos, and ethoprop. They are used primarily in California on a wide variety of fruit, vegetable, and nut crops. “These four pesticides put thousands of farmworkers and their families at risk of serious illness every year,” said Patti Goldman, an attorney for Earthjustice, the environmental law firm that represents the coalition. “It is inexcusable for EPA to allow use of pesticides that they know are harming people, especially children.” EPA has documented that children are especially susceptible to poisoning from organophosphates. Exposure can cause dizziness, vomiting, convulsions, numbness in the limbs, loss of intellectual functioning, and death. Some organophosphates also cause hormone disruption, birth defects, and cancer. “Farmworkers, and all people living in and near agricultural regions, especially children, are at great risk […]