(Beyond Pesticides, May 30, 2024) The House Agriculture Committee voted 33-21 on May 23 to move the Farm, Food, and National Security Act out of committee after a contentious markup and onslaught of amendments that undermine water health, soil health, and local democratic authority to protect people and the environment from toxic pesticide exposure. One of nearly sixty amendments introduced in the markup last week included the continuation of a decade-long attack on National Pollutant Discharge Elimination System (NPDES) permit via Clean Water Act (CWA) for pesticide discharge. What was most illuminating however was not the passage of the bill itself, but Big Agriculture’s raucous approval. Advocates see pesticide industry and its allies’ support for what it is—the reliance on petrochemical-based pesticides leading to economic instability, ecosystem collapse, and the degradation of democratic institutions. With support for entrenched dependency on petrochemical pesticides and fertilizers, the committee’s bill requires taxpayers to pay through the government’s crop insurance program for escalating losses caused by chemical-intensive farming practices, contributing to yield losses that the U.S. Department of Agriculture (USDA) says are “natural causes such as drought, excessive moisture [e.g., floods], hail, wind, frost, insects, and disease. . .” However, the frequency of these […]

(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 24, 2024) Even allegedly “low-toxicity” pesticides such as flupyradifurone (insecticide), azoxystrobin, and difenoconazole (fungicides) pose adverse health effects to solitary ground-nesting squash bees (Xenoglossa pruinose), according to a study published in Biological Sciences. Fungicide exposure led to less pollen collected per flower, while exposure to flupyradifurone (FPF) produced larger offspring (which make it more challenging for them to fly). Simultaneous exposure to the three pesticides “induced hyperactivity in female squash bees relative to both the control and single pesticide exposure, and reduced the number of emerging offspring per nest compared to individual pesticide treatments.” With United Nations Food and Agriculture Organizations-sponsored World Bee Day earlier this week, now more than ever advocates are calling for the elimination of toxic insecticide classes, such as neonicotinoids and butanolides, and their wholesale replacement with organic land management principles. This study was written by Sabrina Rondeau, PhD, postdoctoral Fellow in the Department of Biology at the University of Ottawa, and Nigel E. Raine, PhD, professor at University of Guelph’s School of Environmental Science. Published on March 20, 2024, the researchers delve into the individual and co-exposure impacts of two fungicides and one insecticide, which is important, given the documented synergistic effects […]

(Beyond Pesticides, May 23, 2024)  A study recently published in the journal Nature compared the impact of organic and conventional food production using eight environmental health indicators and found that organic food has a significantly lower environmental impact than conventional food production for six of the eight indicators, including a lower potential for contributing to acidification of the environment, energy use, and biodiversity loss. For the analysis, scientists reviewed 100 different “life cycle assessments” (LCA) of organic and conventionally grown food products from cradle-to-farm gate.    LCA is a commonly used methodology to estimate food production system impacts on the environment through resource depletion and pollutant emissions. The results—that organic food production is less impactful on the environment—add to the robust body of research that underscores the importance of organic farming to the development of a sustainable global food system while addressing climate change. Beyond Pesticides has long argued that one of the most powerful tools in fighting global warming is organic agriculture, as it sequesters atmospheric carbon, eliminates the use of fossil fuel-based synthetic fertilizers and synthetic pesticides, and provides environmental and human health benefits. This study and most of the 100 studies it evaluates, do not recognize that conventional […]

(Beyond Pesticides, May 21, 2024) In a first-of-its kind series of biomonitoring studies published in Agrochemicals, researchers identified the presence of the herbicides dicamba and 2,4-D in all pregnant participants from both cohorts in 2010-2012 and 2020-2022. The findings from this research are not surprising given the explosion of toxic petrochemical pesticides in the Midwest region of the United States. “The overall level of dicamba use (kilograms applied in one hundred thousands) in the U.S. has increased for soybeans since 2015 and slightly increased for cotton and corn,” the authors report, based on U.S. Department of Agriculture National Agriculture Statistics Service surveys. “The overall level of 2,4-D use (kilograms applied in one hundred thousands) in the U.S. was highest in 2010 for wheat, soybeans, and corn. The amount of 2,4-D applied increased the most for soybeans and corn from 2010 to 2020.” The researchers focused on the states of Illinois, Indiana, and Ohio, given the increase in dicamba and 2,4-D during the study period for both cohorts (2010-2022). The researchers are based at Indiana University School of Medicine in the Department of Biostatistics and Health Data Science and Department of Obstetrics and Gynecology, Quebec Toxicology Center within the Institut national […]

(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 17, 2024) Massachusetts Governor Maura Healey (D) proclaimed May 12 -18, 2024 as Multiple Chemical Sensitivity Awareness Week, first established in 1998 in numerous states across the U.S. Multiple Chemical Sensitivity (MCS)—also called chemical intolerance or Toxicant-Induced Loss of Tolerance (TILT), is characterized by disorders in one or more body systems, including respiratory, gastrointestinal, musculoskeletal, and neurological processes. It is thought to be caused by adverse reactions to environmental chemicals and/or biological substances such as mold. Affected individuals suffer fatigue, rashes, muscle and joint pains, memory loss, and other symptoms. The Massachusetts proclamation encourages “residents of the commonwealth to take cognizance” of the event and recognize the distress of their fellow citizens who suffer from MCS. May 12 is also known as International May 12th Awareness Day, an observance started in 2006 in the United Kingdom to educate the public about many diseases associated with sensitivity to chemicals, including MCS, fibromyalgia, and Gulf War Syndrome. While some scientists have considered MCS a psychological or psychosomatic problem, there is increasing support for the reality of MCS as a physical disease distinct from mental or emotional disorders. Yet there are no medical tests that can reliably confirm a diagnosis, […]

(Beyond Pesticides, May 15, 2024) A study published recently in the journal Environmental Research finds a significant correlation between exposure to certain pesticides and an elevated risk of inflammatory bowel disease (IBD), a chronic autoimmune condition of the gastrointestinal tract. The study, adding to the body of science on this subject, evaluates self-reported data from licensed pesticide applicators and their spouses exposed to pesticides for over 20 years. In addition, while some of the chemicals found to be most closely associated with incidents of IBD have been banned from use, they are “forever” chemicals that persist in the environment for generations. These findings demonstrate once again the failings of the current regulatory process to identify hazards before they are put into the environment. The study found evidence that exposure to several organochlorine insecticides (dieldrin, DDT, and toxaphene), as well as organophosphate insecticides (parathion, terbufos, and phorate) and herbicides (2,4,5-T, 2,4,5-TP, and metolachlor), is associated with elevated IBD risk. IBD is a generic term for diseases that result in chronic inflammation of the gastrointestinal tract, such as Crohn’s disease and ulcerative colitis. It is estimated that 6.8 million patients globally suffered from IBD in 2017. IBD may result from an imbalance […]

(Beyond Pesticides, May 14, 2024) As research continues to emerge on the value of organic farming, U.S. Congress debates its future as Farm Bill negotiations have been stalled for months. Recent studies published within the past few months show the significance of organic agriculture’s support of fungal and microbial life, which is essential to soil health. Meanwhile, last week the Democrat-led Senate and Republican-led House of Representatives presented their respective visions to amend the 2024 Farm Bill. The office of U.S. Senator Debbie Stabenow (D-MI), chair of the Senate Agriculture Committee, released an initial Senate framework for the (now 2024) Farm Bill. At the same time, U.S. Representative Glenn Thompson (R-PA), chair of the House Agriculture Committee, released an outline of the House version, then followed up with more details. While the Senate Democratic proposal includes more robust support for expanding and strengthening organic product supply chains and domestic production, the House Republican support for organic land management principles and practices demonstrates that the Farm Bill could recognize, across the political spectrum, its economic, ecological, and public health benefits in the United States. Despite this, a growing coalition of advocates is alerting the public and members of Congress that the […]

(Beyond Pesticides, May 13, 2024) A study published in Environmental Research finds that “early life organophosphate pesticide exposure has been linked with poorer neurodevelopment from infancy to adolescence.” Researchers in this study acknowledge that there is still much more to be done in furthering understanding of “neural mechanisms underlying these associations,” and yet there is “notable consistency” in their Center for the Health Assessment of Mothers and Children of Salinas (CHAMACOS) birth cohort study. This study’s findings are consistent with decades of substantial, peer-reviewed scientific literature documenting the adverse health impacts of organophosphate pesticides on public and ecological health. Organic advocates believe that a transition away from chemical-intensive agriculture and land management is the most viable solution to avoid adverse health impacts and end reliance on toxic chemicals in households and communities. The researchers for this study are based at the University of California, Berkley (Center for Environmental Research and Community Health as well as Center for Interdisciplinary Brain Sciences Research), Department of Public Health at University of California, Merced, and Stanford University (Departments of Radiology and Pediatrics in the School of Medicine). “We have reported associations of prenatal [organophosphate] exposure with poorer cognitive function and executive function, and more attention and […]

(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, May 7, 2024) The marginal user costs (MUC) of pesticide resistance for chemical-intensive farmers and the pest management industry are significantly affected by pesticide costs, density dependence (growth rate of a pest population impacted by its density), and dominant genetic mutations that cause resistance, according to a novel study published in Journal of the Agricultural and Applied Economics Association. Although the authors believe that integrated pest management (IPM) can be fine-tuned based on these findings, many advocates believe that these findings in fact underscore the importance of eliminating toxic pesticide use amidst compounding climate, biodiversity, and public health crises—which many IPM strategies do not adequately address. As the costs of petrochemical-based pesticides increase, organisms identified as pests continue to increase in population density as global and regional temperatures dually increase. Organic agriculture, and organic land management principles more broadly, are an economically and ecologically advantageous leap ahead in transitioning to a food system that moves beyond the status quo that poisons people and the planet. “This paper seeks to develop a better understanding of how the user costs of resistance are potentially determined by the interactions of heterogeneous bioeconomic factors that vary by context,” say the study authors. […]

(Beyond Pesticides, May 6, 2024) The pattern of failure to protect the public from pesticides is again brought to public attention by an analysis by Consumer Reports (CR) that effectively updates its previous report released in 2020. The report and its earlier iteration identify deep structural weaknesses with the institutions charged with protecting the public’s health and safety. The health risks outlined by CR in 2020 and related to ongoing pesticide exposure, even at low levels, include cardiovascular diseases, cancers, reproductive dysfunction, respiratory problems (e.g., asthma, bronchitis), neurological impacts (e.g., developmental effects and dementia/Alzheimer’s), and endocrine dysfunction, among others. Previously, the magazine reported, “CR’s experts say the government hasn’t upheld its responsibility to protect consumers [and that] the research used to set [pesticide residue] tolerances is imperfect, and they’re often too high.” CR has cited the U.S. Environmental Protection Agency (EPA), which is primarily responsible for pesticide regulation, for multiple inadequacies. According to the latest CR analysis, the U.S. Department of Agriculture (USDA) Pesticide Data Program (PDP) Annual Summary has once again failed to accurately portray the safety of some of the most commonly sold fruits and vegetables in the United States. CR reviewed seven years of PDP data, finding that 20% […]

(Beyond Pesticides, May 3, 2024) Parkinson’s disease (PD) is the second most common neurodegenerative disease in the world after Alzheimer’s. Genetic factors account for only a fraction of PD cases, and for decades scientists have been aware of associations between pesticide exposures and PD. Yet, not everyone exposed to pesticides gets PD. Consequently, neither the genetic nor the environmental hypothesis is fully satisfactory; both may be involved. Thus, there has been great interest in identifying gene variants that affect the risks of PD associated with pesticide exposure. Now a team of University of California at Los Angeles researchers led by neurologist Brent Fogel, MD, PhD has traced a connection between certain gene variants and the occurrence and severity of PD in a cohort of central California PD patients who have had long-term exposure to pesticides. The genes are related to autophagy, the process by which cells organize, degrade, recycle or eject molecules to maintain healthy chemical balance. Autophagy is an essential process throughout the body, including regulation of mitochondria, which are also vital for healthy cellular function. The study supports other research suggesting that autophagy is disturbed in neurodegenerative diseases. As Beyond Pesticides discussed in its April 19 Daily News, PD […]

(Beyond Pesticides, May 1, 2024) According to a new analysis by Consumer Reports, the U.S. Department of Agriculture (USDA) Pesticide Data Program (PDP) Annual Summary has once again failed to accurately portray the safety of some of the most commonly sold fruits and vegetables in the United States. A review of seven years of PDP data show that 20% of the foods tested pose a “high risk” to the public and 12 specific commodities are so dangerous that children or pregnant people should not eat more than one serving per day, according to Consumer Reports analysis. Consumer Reports contend that U.S. Environmental Protection (EPA) pesticide residue tolerances are too lenient. To better evaluate potential health risks associated with various foods, Consumer Reports applied stricter residue limits than the EPA tolerances (see here for CR’s analytical methodology). Notably, USDA certified organic food products are not permitted to be produced with the pesticides identified by the report. Pesticide residues found in organic, with rare exception, are a function of the off-target chemical-intensive agriculture pollution through pesticide drift, water contamination, or background soil residues. The Consumer Reports results fly in the face of the rosy outlook reported by the USDA in its 2022 […]

(Beyond Pesticides, April 30, 2024) Researchers found epigenetic changes, including changes relating to “DNA methylation, histone modification, and differential microRNA expression [which ‘can alter the expression of many disease-related genes’],” in a systematic review and meta-analysis of existing literature published in Environmental Epigenetics. “Our review did provide evidence that pesticide exposure could lead to epigenetic modifications, possibly altering global and gene-specific methylation levels, epigenome-wide methylation, and micro-RNA differential expression,” researchers share in the conclusion of the study. This study is an amalgamation of various studies on epigenetic changes based on a literature review process: “Article review involved [3,529 articles found through] extensive searches across major human health databases, including PubMed, Embase, and Cochrane, and BVS (Biblioteca Virtual em Saúde – the Latin American Health Database). Searches covered articles published through December 2020. Considering the diverse terminologies used to describe the same epigenetic mechanism in this field, the search strategy aimed to encompass all relevant articles by combining a variety of search terms in titles and abstracts. This approach was implemented across PubMed, Embase and Cochrane databases to ensure comprehensive coverage.” Studies were not included if the participants were not considered “healthy individuals” or if the participants had “known inherent/congenital or […]

(Beyond Pesticides, April 29, 2024) The contamination and poisoning left behind from wood treatment sites, resulting in hundreds of designated Superfund clean-up sites across the country, is the subject of an action by Beyond Pesticides after the release of yet another report criticizing the federal government’s inadequate response to the public’s risk to “residual contamination in the groundwater and soil” by the U.S. Environmental Protection Agency (EPA) Office of Inspector General (OIG). The report criticizes EPA’s weak response at the American Creosote Works Superfund site in Pensacola, FL, a problem that reflects the unending dangers of sites contaminated with persistent toxic chemicals associated with wood preservatives. The site was put on the Superfund priority list in 1983 and in 2017 it was estimated that the clean-up would cost $35.3 million. Just last year, EPA Administrator Michael Regan toured another Superfund Site contaminated with creosote and pledged the clean-up of that site, which affects a community of predominantly people of color. Tell EPA to cancel the registration of highly toxic wood preservatives, including creosote, chromated arsenicals, and copper compounds, and the U.S. Congress to ensure the prevention of future site contaminations. As long as dependency on toxic wood preservatives (used on utility […]

(Beyond Pesticides, April 26, 2024) Researchers build on existing research when assessing the relationship between long-term exposure to organophosphorus pesticides—widely used in food production and homes and gardens—and the human gut microbiome. In a new study published in Environmental Health, an interdisciplinary research team from University of California, Los Angeles determined, “that exposure to [organophosphorus pesticides] is associated with changes in the abundance of several bacterial groups and differential functional capacity in metabolic pathways supported by the human gut microbiome.” The study draws upon data from a “Parkinson’s, Environment and Gene study (PEG)” in which 190 participants were asked to submit fecal samples and answer interview questions. “[The study] was initially designed to investigate the etiology of Parkinson’s disease (PD) and participants were recruited in two study waves [‘over the full 10-year exposure window’]: 2001–2007 and 2012–2017. At baseline, [Parkinson’s disease] patients were diagnosed within the past 5 years and randomly selected community controls were also recruited,” the research team shares in their Methodology section. “Since 2017, we invited previous study participants who could be contacted to enroll in a pilot study of the gut microbiome. In addition, we invited a household or community member of [Parkinson’s] patients to participate.” […]

(Beyond Pesticides, April 23, 2024) The Office of Inspector General for the U.S. Environmental Protection Agency (EPA) released a report last week finding that the agency has failed to establish “institutional controls” at the American Creosote Works Superfund Site in Pensacola, Florida, leading to continuous groundwater and soil contamination that “leav[es] the public at risk of exposure.” The 1980 Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) established the Superfund program, codified under 42 U.S.C. Chapter 103, to clean up contaminated sites with tax money from polluting industries. The OIG made eight recommendations for the regional EPA administrator and one for the assistant administrator “for Land and Emergency Management to improve the institutional controls at American Creosote Works Superfund Site.” There are three main determinations found in the results section of the OIG report: first, the institutional controls to prevent potential exposure were either “insufficient or unimplemented;” second, the EPA missed its mark in communicating associated risks to the public in areas surrounding this Superfund site; and third, the full administrative record for this site was not available at the time of inspection. This report builds on what advocates argue is the sustained legacy of EPA inaction and failure to […]

(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 19, 2024) Parkinson’s disease (PD) and certain forms of dementia have been associated with exposure to pesticides, industrial chemicals, and air pollution for decades. But the mechanisms of disease progression have been unclear, and U.S. regulators have been reluctant to recognize the risks. Now neurologist E. Ray Dorsey, MD of the University of Rochester and researchers from the University of Alabama at Birmingham and Aarhus University in Denmark propose a new research paradigm based on tracking how toxicants cause neurodegeneration through inhalation and ingestion pathways. The paradigm, the authors believe, can be used to gain insight into how PD and a form of dementia known as Lewy body disease (LBD) are initiated as many as 50 years before the onset of symptoms. Dorsey and colleagues build on a recent theory that PD and LBD may be two versions of the same basic disease, both involving Lewy bodies in the nervous system. The group’s proposal was published in the Journal of Parkinson’s Disease in April. If its recommended research agenda produces the anticipated empirical support, the new paradigm will demand integration of many interdisciplinary lines of evidence showing that environmental exposures to synthetic chemicals may be the primary cause […]

(Beyond Pesticides, April 18, 2024) University of Michigan researchers have found a statistically significant relationship between heightened risk of amyotrophic lateral sclerosis (ALS) and household exposure to lawn care products and pesticides. The study results were published earlier this month in Amyotrophic Lateral Sclerosis and Frontotemporal Degeneration. The interdisciplinary research team concludes that modifying residential exposure to toxic substances, including pesticides, can play an important role in ALS susceptibility and prognosis. The results build on a substantial body of scientific literature identifying pesticide exposure in various ALS cohort studies. Advocates say that these adverse effects, along with other numerous health and environmental effects, inform their call for the phaseout of toxic pesticide use and the adoption of alternative practices and eco-compatible products. All participants in this study are patients at the University of Michigan Pranger ALS Clinic with Gold Coast ALS diagnosis, which according to a Muscle & Nerve study refers to the identification of two factors: “progressive motor impairment documented by history or repeated clinical assessment” and “the presence of upper and lower motor neuron dysfunction in a least one body region.” All 367 ALS and 255 control patients were tasked with completing a survey in which they self-reported […]

(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 […]