(Beyond Pesticides, September 16, 2024) After the release of a hard-hitting study last week published in Science that pinpoints the cycle of increasing pesticide use with ecosystem and bat decline, resulting in higher infant mortality, Beyond Pesticides is calling for state and local action to transition public land to organic practices. Without a healthy ecosystem, the study documents increased pesticide use with dramatic adverse health effects. To take corrective action, Beyond Pesticides’ action asks governors and mayors to do the following: Eliminate the use of pesticides that imperil bats by adopting biodiversity conservation goals including— (1) ecological mosquito management with measures that recognize the benefit of preventive strategies, establish source reduction programs to manage breeding sites on public lands, educate on the management of private lands, employ programs for larval management with biological controls, and eliminate the use of toxic pesticides; (2) prohibition of systemic insecticides and treated seeds, including neonicotinoids; and (3) land management on public lands—including hospitals, higher education institutions, schools, and parks—using regenerative organic principles and organic certified practices and products, to transition to a viable organic system that prioritizes long-term health of the public, ecology, and economy. The new research connects declines in bat populations with increased […]

(Beyond Pesticides, September 9, 2024)  Comments are due by 11:59 PM EDT on September 30, 2024. With the opening of the public comment period on organic standards that determine the integrity, strength, and growth of the organic agricultural sector, a study was released last week that shows degradation of the ecosystem linked to increased infant mortality associated with higher pesticide use by chemical-intensive farmers compensating for losses in bat populations. It is well known that bats, among other wildlife including birds and bees, provide important ecosystem services to farmers by helping to manage pest populations and increase plant resilience and productivity. While degradation of ecosystems is attributable to many factors, pesticide use accounts for an important element in harm to bats and biodiversity. The study, “The economic impacts of ecosystem disruptions: Costs from substituting biological pest control,” published in Science, concludes with a finding  that “insect-eating bat population levels induce farmers to substitute with insecticides, consequently resulting in a negative health shock to infant mortality.” Daily News will cover this study in depth in an upcoming edition. According to research published in the Journal of the Association of Environmental and Resource Economists (2022), bat population declines cost American farmers as much as […]

(Beyond Pesticides, August 30, 2024) There is no more compelling reason to embrace a precautionary pesticide poisoning standard this Labor Day than the need to protect workers. In fact, the Occupational Safety and Health Administration (OSHA) says on its website, Transitioning to Safer Chemicals, that the best way to protect workers is to  “eliminate or reduce hazardous chemicals at the source.” While some try to employ product substitution with “safer” chemicals, Beyond Pesticides urges decision makers to embrace alternative systems, such as organic management systems, that embrace management techniques to meet disease and infestation management goals and use only organic compatible substances. According to OSHA: “In chemical management, [the industrial hygiene principle, known as the hierarchy of controls] guides employers and workers to eliminate or reduce hazardous chemicals at the source by substituting them with safer alternatives. Unlike traditional engineering controls, administrative controls, work practice controls, or personal protective equipment, these strategies can completely eliminate exposure to hazardous chemicals, reduce the potential for chemical accidents, reduce disposal costs, and remove concerns regarding worker compliance and equipment maintenance.” A look through the state and federal databases that track occupational pesticide poisoning for both acute (immediate short-term) and chronic (long-term) pesticide effects […]

(Beyond Pesticides, August 26, 2024) In July, the U.S. Environmental Protection Agency (EPA) announced it was raising the allowable levels of the highly toxic weed killer atrazine in the nation’s waterways from the 2016 level of 3.4 to 9.7 micrograms per liter (µg/L), which scientists and environmental advocates say is a serious threat to aquatic plants, fish, invertebrates, and amphibians, in addition to people who recreate in waterways or eat food from them. With EPA’s August 7 decision to ban the weed killer Dacthal (or DCPA–dimethyl tetrachloroterephthalate), Beyond Pesticides is rallying public support for the removal of atrazine from the market under the same standards of harm, inability to mitigate hazards, and the availability of alternatives. As Beyond Pesticides points out in its 2022 atrazine comments (2020 and 2016 comments included) to EPA, the agency in November 2021 released the final Biological Evaluation (BE) assessing risks to listed species from labeled uses of atrazine (in the triazine chemical family). The agency made “likely to adversely affect (LAA) determinations” for 1,013 species and 328 critical habitats, which it is now rejecting, while using a “community-equivalent level of concern (CE-LOC)” measure that is filled with uncertainty and lacks any sense of precaution with […]

(Beyond Pesticides, August 19, 2024) As a local news outlet in Virginia covers a local farm receiving organic certification, Beyond Pesticides launches an action this week to “take back organic” —in response to prominent agricultural forces and industry interests attempting to weaken organic standards and blur the line between certified organic and “regenerative” practices that are not organic-certified. In an article, VMRC’s Farm at Willow Run is certified organic [VMRC is the Virginia Mennonite Retirement Community], Rocktown Now quotes the farm manager in Harrisonburg, VA, Nate Clark, saying, “This milestone demonstrates our dedication to providing high-quality, healthy food to our residents and community while also prioritizing environmental sustainability.” The article reports that as a certified organic farm with detailed records of the farm’s field and harvest activities and materials, subject to annual inspections, “VMRC is committed to regenerative farming practices that promote soil health, energy conservation and fair working conditions.” “Regenerative” agriculture or land management that is not certified organic raises a series of questions about its lack of a standard definition that is enforceable under a compliance system. Beyond Pesticides’ piece on the subject, “Regenerative” Agriculture Still Misses the Mark in Defining a Path to a Livable Future,“ explores […]

(Beyond Pesticides, August 12, 2024)  When the U.S. Environmental Protection Agency (EPA) issued an emergency ban of the weed killer Dacthal (DCPA) last week, it said that there are no “practicable mitigation measures” to protect against identified hazards—a clear and honest assessment of the limits of pesticide product label changes and use restrictions. Now, the question is whether the same thinking can be applied across the EPA’s pesticide program, addressing the urgent need to protect biodiversity. In the Dacthal proclamation, EPA said it consulted with the U.S. Department of Agriculture (USDA) on “alternatives to this pesticide,” and presumably determined that there were “alternative chemicals” that could be used in chemical-intensive agriculture—while not considering “alternatives to chemicals.” This is the framework that is understood to be EPA’s process that keeps pest management on a pesticide treadmill except in extremely rare cases (this being the second in nearly 40 years). It is also the framework that has led to catastrophic events or existential crises on biodiversity collapse, health threats, and the climate emergency. On biodiversity, the mix of diverse and intricate relationships of organisms in nature that are essential to the sustaining of life, EPA’s pesticide program, the Office of Pesticide Programs, has […]

(Beyond Pesticides, August 5, 2024) As the longstanding problem of involuntary pesticide exposure through chemical drift continues unabated, EPA announced “new, earlier protections” that are being criticized by Beyond Pesticides as inadequate. The organization is calling on the public to let EPA and Congress know that it must comprehensively eliminate nontarget chemical trespass. Beyond Pesticides notes that the recent EPA announcement does not stop the movement of pesticides off the target sites restricted by pesticide product labels and therefore does not protect the public and environment in agricultural, rural, suburban, and urban areas from resulting health and ecological threats. EPA’s July 15, 2024, press release, “EPA Announces New, Earlier Protections for People from Pesticide Spray Drift” states, “The Agency is not making any changes to its chemical-specific methodology outlined in the 2014 document but has decided to extend the chemical-specific spray drift methodology to certain registration actions.” Although EPA should evaluate every pesticide use for its drift potential, extension of an inadequate process does not constitute “protection.” >> Tell EPA and Congress that EPA must protect against all forms of pesticide drift. Pesticide drift—more properly designated “chemical trespass”—is a threat to people living in agricultural, rural, suburban, and urban areas, […]

(Beyond Pesticides, July 29, 2024) Beyond Pesticides is asking the public to support a petition to the U.S. Environmental Protection Agency (EPA), filed by environmental and farm groups, to require the agency’s pesticide registration program to ban PFAS (so-called “forever chemicals”) as pesticide ingredients and all their uses that result in contamination of pesticide products. The petition, submitted by the Center for Food Safety (CFS) on behalf of 12 other petitioners, asks EPA to: “(1) ban PFAS as pesticide ingredients; (2) adopt a broad definition of PFAS chemicals that reflect the current scientific understanding of the class of chemicals; (3) prohibit the use of PFAS-containing containers for pesticide storage; (4) mandate reporting of PFAS contamination from pesticide registrants; and (5) prevent future contamination by requiring pesticide manufacturers to submit data specific to PFAS before future registrations can be approved.” PFAS—per- and polyfluorinated substances—is a group of nearly 10,000 highly persistent, human-made toxic chemicals. A commentary released last week in Environmental Health Perspectives, Forever Pesticides: A Growing Source of PFAS Contamination in the Environment, “explore[s] different ways that PFAS can be introduced into pesticide products, the extent of PFAS contamination of pesticide products, and the implications this could have for human […]

(Beyond Pesticides, July 15, 2024) It is hot. Really hot. A serious response to this climate emergency requires, according to environmental advocates, a dramatic transformation in land management and an end to the use of petrochemical pesticides and fertilizers. Beyond the real-world adverse effects of the climate crisis— more intense and frequent fires, floods, hurricanes and hail storms, as well as the harm to health and biodiversity—the rising insurance premiums imposed by the insurance industry speaks to the need for an urgent systemic response. According to the paper, Pricing of Climate Risk Insurance: Regulation and Cross-Subsidies, “The unprecedented rise in natural disasters has led to catastrophic losses of more than $600 billion in the United States over the last two decades, roughly twice the losses of the previous 40 years combined.” While the events associated with climate are more accurately described as “human-made” rather than “natural” disasters, a 2023 Washington Post article reports that, “U.S. insurers have paid out $295.8 billion in natural disaster losses from 2020 to 2022, a record for a three-year period.” This has led to dramatic changes in the cost of insurance coverage and the decision of many carriers to deny coverage. The Washington Post writes, “At least […]

(Beyond Pesticides, July 8, 2024) Please submit comments by Wednesday, July 31, 2024. Acephate, an insecticide and member of the highly toxic organophosphate (OP) family, is so toxic that EPA is proposing to ban all uses except the systemic injection into trees. A comment period is open, and EPA is accepting comments through Wednesday, July 31, after extending the earlier July deadline. With this remaining use, EPA is still not recognizing that systemic neonicotinoid pesticides can cause serious environmental harm to the ecosystem through indiscriminate poisoning of organisms. >> Submit a comment on acephate and tell EPA that no pesticide should be allowed to be used if the crop can be produced organically.  EPA proposes to cancel all uses of acephate other than tree injection to eliminate all risks of concern it has identified that exceed its level of concern for dietary/drinking water risk, residential and occupational risks, and risks to non-target organisms. As Beyond Pesticides points out, although the tree injection method does not pose excessive dietary or aggregate health risk and does not pose any untoward occupational or post-application human health risks of concern, there are significant ecological risks posed that the agency has neglected. Rather than assessing the ecological risks of tree […]

(Beyond Pesticides, July 4, 2024) In reflecting on recent U.S. Supreme Court decisions that reduce federal government powers to restrict hazardous chemicals, including pesticides (see Clean Water Act decision and federal restrictions of toxic hazards under the reversal of Chevron decision), two remaining authorities in state and local governments and in the courts have become the next battleground to protect health and the environment. What is at stake are two major backstops to weak federal controls and chemical company disregard for safety: the critical importance of state and local governments’ exercise of authority to restrict toxic chemicals, and the ability of people to sue corporations for their failure to warn about their products’ hazards.  The attack on state and local authority in the Farm Bill The Farm Bill in the U.S. House of Representatives: Prohibits the rights of states and local governments to restrict pesticides and protect public health and the environment. The language says the Farm Bill will “prohibit any State, instrumentality or political subdivision thereof… from directly or indirectly imposing or continuing in effect any requirements for, or penalize or hold liable any entity for failing to comply with requirements with respect to, labeling or packaging that is in […]

(Beyond Pesticides, July 1, 2024) Comments on proposed new dicamba uses are due Friday, July 5 The U.S. Environmental Protection Agency (EPA) is accepting public comments until July 5 on whether it should allow the expanded use of the weed killer dicamba, which has been associated with adverse impacts related to its propensity to drift off of the target application site. The comment period addresses a BASF chemical company proposal for additional food use of a dicamba product on dicamba-tolerant cotton and dicamba-tolerant soybeans. (See Beyond Pesticides’ comments.) This application is similar to Bayer CropScience’s application for XtendiMax®, for which Beyond Pesticides submitted comments in June. The proposed label for BASF’s Engenia® allows for application preplant, at-planting, preemergence, and postemergence (in-crop) for broadleaf weeds. >> Tell EPA to ban use of dicamba and other drift-prone pesticides. The U.S. Supreme Court Reversal This proposal is under consideration on the heels of a U.S. Supreme Court decision on June 28 that reverses a 40-year old decision in Chevron v. Natural Resources Defense Council, which created a deference to federal agencies in the rulemaking process. In the dissent to this 6-3 decision of the court, the dissenters focus on the role of executive […]

Calls for Holistic Environmental Justice and a Shift Away from Societal Dependence on Petrochemical Pesticides and Fertilizers (Beyond Pesticides, June 18-19, 2024) Juneteenth (June 19) commemorates the date in 1865 when the enslavement of Black Americans ended in the westernmost Confederate state of Texas, over two and a half years after the Emancipation Proclamation of 1863 and the defeat of the Confederacy on April 9, 1865. On June 19, 1865, Union Major General Gordon Granger brought federal troops to Galveston, Texas and finally, and belatedly, implemented the Emancipation Proclamation, which proclaimed on January 1, 1863 freedom from slavery across the nation. Carl Mack, PhD, a historian and former President of the Seattle-King County NAACP, reminds us that there were still 225,000 enslaved Black Americans in Kentucky and Delaware after June 19, 1865 and the end of the Civil War until December 6, 1865 when Georgia became the 27th state to ratify the 13th amendment. “That is the day in which Georgia ratified the 13th amendment,” Dr. Mack goes on to discuss the remaining three former border states on their progress in adopting the 13th amendment. “As it applies to Delaware and Kentucky, Delaware did not ratify the 13th amendment until […]

(Beyond Pesticides, June 17, 2024) Every year, Beyond Pesticides announces National Pollinator Week—this year beginning today, June 17—to remind eaters of food, gardeners, farmers, communities (including park districts to school districts), civic organizations, responsible corporations, policy makers, and legislators that there are actions that can be taken that are transformative. All the opportunities for action to protect pollinators, and the ecosystems that are critical to their survival, can collectively be transformational in eliminating toxic pesticides that are major contributors to the collapse of biodiversity. This is why Beyond Pesticides starts most discussions and strategic actions for meaningful pollinator and biodiversity protection with the transition to practicing and supporting organic. In launching National Pollinator Week, Beyond Pesticides makes suggestions for individual actions to increase efforts to think and act holistically to protect the environment that supports pollinators. The impact that people have starts with grocery store purchases and the management of gardens, parks, playing fields, and pubic lands. The introduction of pesticides into our food supply and our managed lands has contributed to a downward spiral that is unsustainable. The good news is that it is now proven that we do not need toxic pesticides to grow food productively and profitably […]

(Beyond Pesticides, June 10, 2024) Expanding the planting of genetically engineered crops is the major focus of “The Coordinated Framework for the Regulation of Biotechnology – Plan for Regulatory Reform under the Coordinated Framework for the Regulation of Biotechnology” (Framework), released in May by three federal agencies. In its Framework, the U.S. Department of Agriculture (USDA), the Food and Drug Administration (FDA) and the U.S. Environmental Protection Agency (EPA) use the words “exempt” or “exemption” in reference to federal safety regulations 21 times. Then, another 21 times the agencies identify their efforts to “streamline” the process for bringing genetically engineered “plant-incorporated protectants” (PIPs) to market. Without including the word “resistance” even once, the Framework advances the interests of the biotech and allied industries, ignoring the serious scientific issues regarding health and environmental effects and the economic failure for farmers facing crop loss. Meanwhile, the issue of resistance is not new to EPA, which has for years acknowledged the resistance problem despite allowing continued weed resistance to weed killers used with herbicide-tolerant crops and insect resistance to the pesticides incorporated into plants.   >> Tell USDA, FDA, and EPA to replace agricultural provisions in the Framework with policies that discourage GE crops […]

(Beyond Pesticides, June 3, 2024) Environmental advocates continue to raise concerns about the Farm Bill (H.R.8467—Farm, Food, and National Security Act of 2024) that emerged from the House Agriculture Committee on May 23 with provisions they say will allow the escalation of environmental threats and then insure big agriculture commodity producers for losses attributable to those environmental disasters through an expansion of USDA’s crop insurance program. Through this taxpayer supported program, USDA covers farm revenue losses due to “natural causes such as drought, excessive moisture [e.g., floods], hail, wind, frost, insects, and disease. . .” Petrochemical pesticide and fertilizer use in chemical-intensive land management and agricultural production contributes to the climate emergency and associated weather, insect, and plant disease threats. Advocates point out that the House Agriculture Committee Farm Bill reduces environmental protections by (i) preempting local and state government authority to allow more restrictive standards at the municipal level, (ii) taking away the right to sue pesticide manufacturers and allied companies for a failure to fully disclose adverse effects of the products they produce or use, and (iii) weakening the regulatory process intended to protect endangered species and biodiversity from pesticides.   Tell Your U.S. Representative and Senators To Support […]

(Beyond Pesticides, May 28, 2024) Public comments are due May 29, 2024. With 40 percent of all vegetables grown in the U.S. coming from the state of California, the current state level process to define “regenerative agriculture” could have major impact on land management practices that address the current climate, biodiversity, and health crises. That is, according to advocates, if the process, directed by the California Department of Food and Agriculture (CDFA) departs from a history of poorly defined and unenforceable terms like Integrated Pest Management (IPM) and Sustainable Agriculture. Virtually all consumers of food have a stake in the outcome of the definition of “regenerative,” so the current public comment period, which closes tomorrow, May 29, 2024, can help influence the outcome. As Beyond Pesticides has reported previously, the term “regenerative” is now increasingly being advanced as a loosely defined alternative to the organic standard and label, which is transparent, defined, certified, enforced, and subject to public input. The  publication AgFunderNews (AFN) in February published its updated “2024 list of agrifood corporates making regenerative agriculture commitments,” a who’s who of the largest food and agribusiness corporations worldwide. The list includes companies such as ADM, Cargill, Danone, General Mills, Tyson, Unilever, Walmart, and more with commitments […]

(Beyond Pesticides, May 20, 2024)  (Beyond Pesticides, May 20, 2024) The Republican Farm Bill draft in the U.S. House of Representatives, released on Friday, May 17, is a broad attack on pesticide restrictions and the right to sue chemical manufacturers and allied users of pesticides when harmed. “This legislation is a complete nonstarter for the millions of people who want stronger pesticide restrictions, democratic decision making on toxic chemicals in communities, and the right to sue manufacturers and pesticide users when harmed and misled on the hazards of pesticides,” said Jay Feldman, executive director. “We vehemently oppose this Republican legislation with the understanding and experience—bridging farmers, medical practitioners, land managers, local policy makers, and families—that we can and must transition to safe practices and products that protect our health, biodiversity, and climate,” Mr. Feldman continued. The Farm Bill attack takes place on many critical fronts. The draft legislation: 1. Takes away the right to sue for failure to warn when harmed by pesticides. The language says: “prohibit. . .a court from directly or indirectly imposing or continuing in effect any requirements for, or penalize or hold liable any entity for failing to comply with requirements with respect to, labeling or […]

(Beyond Pesticides, May 8-9, 2024) In its proposal on mushrooms and pet food, the U.S. Department of Agriculture’s (USDA) National Organic Program is following up on recommendations of the National Organic Standards Board (NOSB) to ensure that two areas of organic production are clarified and in compliance with the Organic Foods Production Act (OFPA). The notice raises questions of standards that ultimately grow the organic market while ensuring that the USDA organic label is backed by standards that have integrity and garner the public’s trust. In this spirit, Beyond Pesticides participates in the NOSB review/recommendation process and USDA rulemaking through public comments. [Note: Beyond Pesticides has served on the NOSB for a five-year term (2010-2015) and urges other environmental organization representatives to consider self-nominating for service on the board.] The issues relating to clear standards for mushrooms and pet food have been before the NOSB and in discussion for some time as a part of ongoing efforts to ensure continuous improvement of standards governing the organic sector. While virtually all in the organic community and industry agree that the USDA proposals are needed and long overdue, Beyond Pesticides points to problems in the proposed rule that need correcting: (i) Re. […]

(Beyond Pesticides, April 22, 2024) Today, on Earth Day, the future of the planet and the health of all its inhabitants come into focus from numerous human and ecosystem health perspectives, with particular concern for the health of the next generation—as childhood cancer continues to be a leading cause of death from disease among children. Many studies demonstrate an association between environmental or occupational pesticide exposure and the risk of childhood cancer in offspring. Taking Action in Your Community: On Earth Day, Beyond Pesticides invites communities to join together in its nationwide campaign to convert parks to organic land management practices through the Parks for a Sustainable Future program. Through this program, Beyond Pesticides works with park managers, bringing hands-on horticultural support to eliminate petrochemical pesticides and fertilizers and instead nurture soil organisms to cycle nutrients naturally while creating resilient landscapes that resist weeds, insects, and disease. This program outlines the steps to become a parks advocate and how Beyond Pesticides works with communities committed to safe parks and playing fields for communities, children, and pets. One major impetus for the Parks program are the many studies that find prenatal and early-life exposure to environmental toxicants increases disease susceptibility. For decades, studies have […]

(Beyond Pesticides, April 17, 2024) With headlines drawing public attention to the contamination of drinking water after years of federal government neglect, the U.S. Environmental Protection Agency (EPA) announced on April 10 new standards to reduce public exposure to PFAS, or per- and polyfluoroalkyl substances, commonly referred to as “forever chemicals” because of their persistence. EPA has finalized a National Primary Drinking Water Regulation (NPDWR) for six PFAS, including PFOA and PFOS, which EPA has recognized have no safe level of exposure, regulating new chemicals for the first time since the 1996 amendments to the Safe Drinking Water Act (SDWA). PFAS persistence and bioaccumulation in humans, wildlife, and the environment is due to the strength of a resulting fluorine–carbon atom bond. PFAS contamination of drinking water, surface and groundwater, waterways, soils, and the food supply—among other resources—is ubiquitous worldwide. PFAS is used in everyday products, including cookware, clothes, carpets, as an anti-sticking and anti-stain agent, in plastics, machinery, and as a pesticide. The action was welcomed by environmentalists and public health advocates as an important step but left many concerned that any level of exposure to these chemicals is unacceptable and critical of EPA’s ongoing failure to act despite years […]

(Beyond Pesticides, April 8, 2024) When Mexico in 2020 decided to protect its traditional varieties of corn for reasons of health, safety, environmental protection, and food sovereignty with the banning of the importation of genetically engineered (GE or GM-genetically modified) corn by 2024, the powerful biotech industry and the U.S. government began a concerted campaign to stop the country’s efforts. With the opposition spearheaded by BIO, “the world’s largest trade association representing biotechnology companies, academic institutions, state biotechnology centers and related organizations across the United States and in more than 30 other nations” (as described in its March 15 press release), including companies like Bayer/Monsanto, the U.S government is calling Mexico’s action a trade barrier. The U.S. is invoking the U.S.-Mexico-Canada Agreement (USMCA), the trade agreement that replaced the North America Free Trade Agreement (NAFTA) in 2020. This is just one of the latest examples of corporate power reigning over U.S. environmental and economic policies. Mexico has already announced a delay in the planned April 1 ban on the importation, production, distribution, and use of glyphosate. Interestingly, this is all happening despite reports that the Biden administration is seeking to “tackle corporate abuses,” which is apparently limited  to tax reform and […]

(Beyond Pesticides, April 1, 2024) Comments are due 11:59 pm EDT, Wednesday, April 3. For the public comment period—deadline Wednesday, April 3—in the lead up to the National Organic Standard Board (NOSB) meeting, advocates have identified the following priority issues: Getting plastics our of organic; Removing endocrine disrupting nonylphenols (NPs) and nonylphenol ethoxylates (NPEs) iodine from dairy production and replace with available alternatives; and Continuing to improve the science supporting ongoing decisions of the NOSB. (See below for details and opportunity to submit comments on these with one click!) Previously, Beyond Pesticides has reported on three additional priority issues, including; Reject the petition to allow unspecified “compostable materials” in compost allowed in organic production; Eliminate nonorganic ingredients in processed organic foods as a part of the Board’s sunset review of allowed materials; and  Ensure that so-called “inert” ingredients in the products used in organic production meet the criteria in OFPA with an NOSB assessment.  (Please see the prior action on these issues and submit comments, if not done previously.) Beyond Pesticides asks the public to join in commenting on priority issues that protect health and the environment as part of the upcoming NOSB meeting. The NOSB is receiving written comments from the […]