(Beyond Pesticides, April 6, 2015) Last week, the city council of Portland, Oregon voted unanimously to ban the use of neonicotinoid insecticides on city-owned property because these pesticides are persistent in the environment, harmful to pollinators, and have been involved in acute bee kills in other areas of the state. Neonicotinoids affect the central nervous system of insects, resulting in paralysis and eventual death. These pesticides have consistently been implicated as a key issue in pollinator declines, not only through immediate bee deaths, but also through sublethal exposure that causes  changes in bee reproduction, navigation, and foraging. The science has become increasingly clear that pesticides, either working individually or synergistically, play a critical role in the ongoing decline of honey bees.   Pesticide exposure can impair both detoxification mechanisms and immune responses, rendering bees more susceptible to viruses, parasites, and other diseases, and leading to devastating bee losses. Portland’s ordinance was spurred in part by the 2013 deaths of tens of thousands of bees as a result of the improper use of the neonicotinoids. Last month state officials banned  four   of the bee-killing insecticides, including   imidacloprid, clothianidin, thiamethoxam and dinotefuran from  use on  Linden  trees. In addition to […]

(Beyond Pesticides, April 3, 2015) Earlier today the U.S. Environmental Protection Agency (EPA) announced a moratorium on new bee- and bird- harming neonicotinoid pesticide products and uses. While supportive of the partial halt on new registrations, farm, beekeeper and environmental groups were have urged EPA to suspend the huge numbers of other bee-harming pesticides already on the market. EPA’s announcement may  foreshadow broader recommendations from the White House Pollinator Health Task Force, according to the alliance. “We need EPA to protect bees and other pollinators from the neonicotinoids and other bee-harming insecticides that are already covering the corn and soybean acres in our area, not just keep new products off the market,” said Joanna Voigt, program and communications coordinator at Kansas Rural Center. “Here at the Kansas Rural Center we work with farmers who rely on pollinators to cultivate crops like squash, blueberries, apples, cucumbers, peppers, sunflowers and more. These farmers deserve more from EPA.” Over 125 farmer, food safety, beekeeper, faith and environmental groups sent a letter to the president last month urging a moratorium on all neonicotinoids and their chemical cousins, other systemic pesticides. Additionally, more than four million Americans signed petitions urging the Obama administration to take […]

(Beyond Pesticides, March 31, 2015) A world renowned entomologist, who reevaluated data from a controversial study on neonicotinoid insecticides, has concluded that UK government scientists misinterpreted the findings when they  concluded that restrictive policy wasn’t necessary on the bee-killing pesticide. David Goulson, Ph.D., a bee researcher and professor at the University of Sussex in Falmer, said the UK was wrong in its position, based on the new analysis. Neonicotinoids have been found by a growing body of scientific literature to be linked to honey bee and pollinator decline. The European Commission voted to suspend the use of neonicotinoid pesticides in 2013 for two years. The ban came several months after the European Food Safety Authority (EFSA) released a report  identifying “high acute risk” to honey bees from uses of certain neonicotinoid chemicals.  However, this action was opposed by the UK government. Despite this opposition, Britain was required  to comply with the ban under European Union (EU) rules. One of the main pieces of evidence informing this opposition is a study published in 2013 by Britain’s Food and Environment Research Agency (FERA), which found  “no clear consistent relationship” between exposure to neonicotinoids and the growth of bee colonies and the number […]

(Beyond Pesticides, March 27, 2015) Portland, Oregon is considering a ban on neonicotinoids, a class of insecticides linked to bee deaths, from use on city property. If the measure passes, Portland will join a long list of towns and communities, including Eugene (Oregon),  Skagway (Alaska),  and, in Washington State, Thurston County,  Seattle, and Spokane. Under the proposed ordinance, city officials would not be permitted to use or buy neonicotinoids or similar pesticides on city lands or in city buildings and would urge stores to label products, such as plants and seeds treated with neonicotinoids. The proposal also applies to city contractors. Additionally, the proposed ban on neonicotinoids and neonicotinoid-like insecticides would not apply immediately to two city rose gardens. Officials say the rose midge, a pest, is difficult to eradicate with the insecticide. Instead the city will look for an alternative method using a pilot project at Peninsula Park in North Portland to test alternative non-toxic insecticides. That proposal would be phased in with a deadline of December 2017 to eliminate all neonicotinoid-based products. The proposal cites seven separate bumble bee incidents in Oregon related to the application of neonicotinoids on trees since June 2013, documented by the state’s Department […]

(Beyond Pesticides, March 25, 2015) Several environmental and food safety groups released new polling data which shows the public believes bee decline issues are critical and linked to pesticide use. This comes as concerned citizens flooded the White House this week with more than 3,500 phone calls demanding action against bee-harming chemicals, ramping up pressure on the Obama administration to protect America’s imperiled pollinators. The poll released yesterday was conducted by the firm FM3 and is being distributed in anticipation of recommendations from the  White House Pollinator Health Task Force. Last year, the President charged this inter-agency task force ””led jointly by the U.S. Environmental Protection Agency (EPA) and the U.S. Department of Agriculture (USDA)”” with implementing a plan to improve the health of bees, butterflies, birds and other pollinating species. According to the poll, an overwhelming majority (86%) say that honey bees and other pollinators are important to our nation’s food supply. More than half of the survey respondents (56%) consider the declining populations of honey bees and other pollinators to be a serious problem ””following only concerns around health care costs (76%) and jobs and the economy (75%), and on par with the problem of gas prices (55%). […]

(Beyond Pesticides, March 23, 2015) The fight to save our bees and other pollinators is at a critical moment. The Obama Administration charged federal agencies with  improving pollinator health this last June, and now, after months of delay, the President’s plan is expected imminently. Your voice is needed because  the chemical  companies that manufacture bee-toxic neonicotinoid pesticides, Bayer and Syngenta, have been working aggressively to  stop the President from taking action to restrict their chemicals, despite the critical threat they pose to bee health. A  week ago, more than four million Americans called on President Obama to take swift action to protect bees from toxic pesticides, and Beyond Pesticides joined with allies to rally in front of the White House to reinforce  this important message. We urgently need to ramp up pressure on the Obama administration to do the right thing for bees and our food system. Call President Obama’s office TODAY to deliver this message. It’s easy, we’ll patch you straight through. Call details: Call number: 1-877-796-1948 Just dial the number, you’ll hear an automated message with instructions and then be patched through to the White House to deliver your urgent message. When you’re connected to the White House, […]

(Beyond Pesticides, March 19, 2015) A federal court ruled Monday against the use of neonicotinoid insecticides linked with destruction of bee colonies and other beneficial insects in national wildlife refuges in the Midwest region.  The ruling caps a legal campaign to end the planting of genetically engineered (GE) crops and other industrial agricultural practices on national wildlife refuges across the country. The federal lawsuit was filed by Center for Food Safety (CFS), Public Employees for Environmental Responsibility (PEER), Sierra Club, and Beyond Pesticides. The suit focused on farming contracts for five refuges in four Midwestern states (IL, IA, MN and MO) and sought to force the Fish & Wildlife Service (FWS), which operates refuges, to stop these practices until it completes rigorous analyses of their environmental impacts. Beset by this litigation, this past July FWS decided that it will phase out the use of GE crops to feed wildlife and ban neonicotinoid insecticides from all wildlife refuges nationwide by January 2016.  This new policy still allows for case-by-case exceptions. In the March 16, 2015 ruling, U.S. District Judge Colleen Kollar-Kotelly ordered: “By no later than APRIL 15, 2015, Defendants shall file a Notice indicating the extent to which neonicotinoid pesticides […]

(Beyond Pesticides, March 13, 2015) Exposure to endocrine (hormone) disrupting chemicals (EDC) results in approximately € 150 billion ($162 billion) in health care costs in the European Union each year, according to panels of scientists tasked by the EU Commission to study their impact. “The shocking thing is that the major component of that cost is related to the loss of brain function in the next generation,” Philippe Grandjean, M.D. of Harvard University, one of the report’s authors, told the Guardian. EDCs, contained in common household products such as detergents, disinfectants, furniture, plastics, and pesticides, interfere with the body’s hormone system either by mimicking naturally produced hormones, blocking hormone receptors in cells, or effecting the transport, synthesis, metabolism or excretion of hormones. These impacts can result in devastating effects on one’s health, including behavioral and learning disorders, such as Attention Deficit Hyperactivity Disorder (ADHD), birth defects, obesity, early puberty, infertility, cardiovascular disease, and childhood and adult cancers. Nearly 100 percent of people have detectable amounts of EDCs in their bodies, according to the introductory guide to EDCs published by the Endocrine Society and IPEN. “Our brains need particular hormones to develop normally —the thyroid hormone and sex hormones like testosterone […]

(Beyond Pesticides, March 6, 2015) Last Friday, Oregon enacted a new rule which bans the use of four types of bee-killing insecticides, including  imidacloprid, clothianidin, thiamethoxam and dinotefuran, regardless of application method on linden trees and other Tilia species. The four insecticides that are now illegal to spray on Tilia trees are all in the neonicotinoid chemical class which are implicated in pollinator decline, and represents a step forward in protecting bees. However, Tilia trees are not the only route of exposure that bees and other pollinators have to neonics, which are currently applied to fields across the U.S. as seed treatment. The rule comes at the request of the Oregon Department of Agriculture (ODA) following several bee-kill incidents in Oregon since June 2013, when more than 50,000 bumblebees were killed after dinotefuran was sprayed on trees in a shopping mall parking lot in Wilsonville, Oregon. After the incident in Wilsonville, ODA initially placed restrictions on two of the chemicals, dinotefuran and imidacloprid on Tilia trees, and the state launched a task force to look at protections for pollinators. The group came out with a range of recommendations including increased outreach and education about bees and support for bee habitat […]

(Beyond Pesticides, March 4, 2015) The 9th U.S. Circuit Court of Appeals has agreed to hear the case brought by beekeepers challenging the U.S. Environmental Protection Agency’s (EPA) approval of a toxic pesticide known to be toxic to bees. In 2013, the beekeepers filed suit against the agency, citing that the new chemical, sulfoxaflor, as further endangering bees and beekeeping and noting that their concerns were not properly addressed by EPA before registration was granted. Sulfoxaflor is a sub-class of the neonicotinoid pesticides that have been linked to global bee declines. The Court has agreed to hear the case on April 14, 2015. The case, Pollinator Stewardship Council v. EPA, which requests changes to EPA’s product label for sulfoxaflor, was first filed July 2013. The petitioners include the Pollinator Stewardship Council, the American Honey Producers Association, the National Honey Bee Advisory Board, the American Beekeeping Federation, and beekeepers Bret Adee, Jeff Anderson and Thomas Smith. The beekeeper groups are represented by Earthjustice. The case is one of a number of pending legal cases on EPA’s pesticide decisions under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), including one submitted March 2013 by Beyond Pesticides, the Center for Food Safety, beekeepers, […]

Congress heeds call to action and introduces legislation as pressure mounts on White House Task Force to issue meaningful recommendations March 4, 2015 (Washington, DC)””A coalition of beekeepers, farmers, business leaders, environmental and food safety advocates rallied in front of the White House and delivered more than 4 million petition signatures today calling on the Obama administration to put forth strong protections for bees and other pollinators. This action anticipates the Pollinator Health Task Force recommendations, expected later this month. The task force, announced by the White House this past June, is charged with improving pollinator health through new agency regulations and partnerships. The assembled groups demand that the recommendations include decisive action on rampant use of neonicotinoids, a class of systemic insecticides scientists say are a driving factor in bee declines. The rally coincided with both a D.C. metro ad campaign and Representatives Earl Blumenauer (D-OR) and John Conyers’s (D-MI) reintroduction of the Saving America’s Pollinators Act, which would suspend the use of four of the most toxic neonicotinoids until the Environmental Protection Agency (EPA) conducts a full review of their safety. Representative Blumenauer, said, “Pollinators are not only vital to a sustainable environment, but key to a stable […]

(Beyond Pesticides, March 3, 2015) Over 125 conservation, beekeeping, food safety, religious, ethnic and farming advocacy groups are urging President Obama and the Environmental Protection Agency (EPA) to take swift and meaningful action to protect honey bees and other pollinators from toxic pesticides. Groups, including Beyond Pesticides, raised their voice through a letter sent in advance of a pending report from the White House Pollinator Task Force, which was established last June by the President with the goal to “reverse pollinator losses and help respond populations to healthy levels.” Last October the White House announced it would miss its self-assigned deadline, delaying the urgent action that is needed to address this crisis. The letter urges President Obama and executive agencies to take action against a class of pesticides called neonicotinoids, systemic poisons that are devastating bee populations. They are also threatening the nation’s food supply, since one-third of the food consumed in the United States is pollinated by bees. “Through bold and decisive action from the White House and EPA, we can begin to reverse bee declines and protect pollinator populations for future generations,” said Nichelle Harriott, Science and Regulatory  Director at Beyond Pesticides. Among other steps the  letter calls […]

(Beyond Pesticides, March 2, 2015) Amid growing consumer backlash, Hershey’s has announced first steps toward moving to non-genetically engineered (GE) ingredients in its chocolate. The news comes in response to tens of thousands of Facebook posts, emails, and telephone calls from consumers who took part in a campaign calling on Hershey’s to move to non-GE ingredients led by GMO Inside. In a statement released February 18, Hershey’s said that it will “transition some of its most popular chocolate brands, including Hershey’s Kisses Milk Chocolates and Hershey’s Milk Chocolate Bars to simpler ingredients.” Last week, Hershey’s confirmed with GMO Inside that as part of its commitment to simpler ingredients, its two iconic products will be non-GE by the end of the year, however the company did not respond to the request to source its sugar organically. “We congratulate Hershey’s on this important move and great first step. As one of the leading chocolate companies in the U.S., this commitment will help move the rest of the companies in this sector,” said Nicole McCann, Green America Food Campaigns Director, “Hershey’s joins General Mills, Unilever, Post Foods, and other leading companies in responding to consumer demand to make at least some of its […]

(Beyond Pesticides, February 27, 2015) New research from the University of Minnesota presents some of the first evidence linking the bee-killing insecticides known as neonicotinoids to monarch butterfly deaths. The study finds that milkweed plants, which monarch butterflies need to survive, may also retain neonicotinoids from nearby plants, making milkweed toxic to monarchs. Monarch population numbers have fallen by 90% in less than 20 years. This year’s population was the second lowest since careful surveys began two decades ago. The critical driver of monarch decline  is the loss of larval host plants in their main breeding habitat, the midwestern Corn Belt. Monarchs lay eggs exclusively on plants in the milkweed family, the only food their larvae will eat. University of Minnesota entomologist Vera Krischik, Ph.D. fed butterflies milkweed plants treated with the neonicotinoid insecticide known as imidacloprid in amounts that might typically be found on backyard plants. While adult monarchs and painted lady butterflies were not affected, which, according to Dr. Krischik, indicates the ability of the adults to detoxify, the larvae of both species of butterflies died. During the course of the study, larvae fed on the treated plants for seven days. “For the monarch, nobody was left that […]

(Beyond Pesticides, February 26, 2015) Yesterday, the Environmental Protection Agency (EPA) granted Florida citrus growers an emergency exemption to use the bee-killing pesticide clothianidin to control Asian Citrus Psyllid (ACP), a pest that causes “citrus greening,” a devastating citrus plant disease. Clothianidin, which is not currently registered for use on citrus, is part of a class of neurotoxic, systemic insecticides called neonicotinoids, which have been implicated in global honey bee declines and suspended in the European Union. “EPA needs to assist in stopping the deadly use of pesticides that harm bees, butterflies, and birds with sustainable practices, rather than imperil pollinators with its decisions,” said Jay Feldman, executive director of Beyond Pesticides, a health and environmental advocacy group. He continued, “We understand the immediate chemical needs of chemical-intensive agriculture for increasingly toxic and persistent chemicals, but urge EPA to help stop the treadmill, lest it allow irreversible harm to the environment, biodiversity, and human health.” Beyond Pesticides is urging EPA to require that growers adopt a management plan in order to apply clothianidin. “Ultimately, EPA should be requiring growers to adopt integrated organic systems to manage pests, as a part of an emergency permit,” said Mr. Feldman. Read Beyond Pesticides’ […]

(Beyond Pesticides, February 25, 2015) The biotechnology industry behind genetically engineered (GE) foods have for years touted that their technology is safe, dismissing any attempts to challenge their science or regulate their material. However, 300 scientists, physicians and scholars assert there is no scientific consensus on the safety of GE foods and find that claims of safety are an “artificial construct that has been falsely perpetuated” through various forums and media. The statement, published in the journal Environmental Sciences Europe and entitled, “No scientific consensus on GMO safety,” cites a concerted effort by GE seed developers and some scientists, commentators and journalists to construct the claim that there is a “scientific consensus” on GE safety, and that debate on the topic is “over.” According to the 13-page statement, 300 independent scientists and researchers felt compelled to develop a document that offered a balanced account of the current state of dissent in this field, based on published evidence in the scientific literature, for both the interested public and the wider science community. They find that a claim of safety “”¦is misleading and misrepresents or outright ignores the currently available scientific evidence and the broad diversity of scientific opinions among scientists on […]

(Beyond Pesticides, February 23, 2015) A Hawaii state House agriculture committee rejected a bill Thursday that sought to impose buffer zones for large agricultural companies that spray restricted-use pesticides near schools and other sensitive areas. The proposal, House Bill 1514, introduced by Rep. Chris Lea, stemmed from concerns about  the impact of genetically-engineered (GE) farming and its inherent dependency on increasing  pesticide use. The measure sought  to require companies’  disclosure of the pesticides used and the volume of use. The bill had strong support from the Hawaii chapter of the national nonprofit Center for Food Safety (CFS), as well as a strong backing from neighbor island residents. Maui, Kauai, and the Big Island have all passed laws recently to regulate the seed industry, but a federal  district  court judge  has ruled  that Hawaii counties do not have that power. Industry has been especially effective in obstructing the bill. CFS’ Hawaii director, Ashley Lukens, said after Thursday’s hearing that she was frustrated by the limited amount of time advocates were given to testify. “It was clear from the very beginning that the hearing was intended to allow the industry to reiterate their talking points,” she said. Not surprisingly, companies (like Monsanto) […]

(Beyond Pesticides, February 20, 2015) A broad-based coalition is urging Canada’s Prime Minister Stephen Harper to put a stop to proposed changes to federal aquaculture regulations, citing damage to the environment and existing businesses. The proposed amendments to the federal Fisheries Act would exempt the aquaculture industry from provisions that “prohibit the release of deleterious substances into water frequented by fish.” Coalition members are worried that the changes will result in pesticides routinely being dumped into the Bay of Fundy,  located between the Canadian provinces of Nova Scotia and New Brunswick, and remove Environment Canada’s role in aquaculture activities, said spokeswoman Maria Recchia, the executive director of the Fundy North Fishermen’s Association. Aquaculture, which refers to the breeding, rearing, and harvesting of aquatic organisms such as fish, shellfish, and plants, provides half of the world’s seafood. According to  Food and Water Watch, offshore aquaculture follows an industrial agriculture model which grows thousands of animals in a confined environment. For fish, however, this confined space is in the ocean, meaning all of the waste products from the operation flow directly into the ocean. This includes excess feed and chemicals that are used, such as antibiotics and pesticides, to treat or prevent […]

(Beyond Pesticides, February 19, 2015) Last week, regulators at the United States Department of Agriculture (USDA) approved a genetically engineered (GE) apple that does not brown after slicing or bruising. The “Arctic” apple, produced by Okanagan Specialty Fruits, is engineered using a novel technique called RNA interference (RNAi). In the case of this GE apple, RNAi technology has been used to silence the genes that produce polyphenol oxidase (PPO), the enzymes responsible for the browning that results after an apple has been bruised. Government approval of this method of genetic engineering is raises serious concerns because of considerable uncertainty regarding the unintended effects of this technology. These concerns are compounded by the agrochemical industry’s future interests in using RNAi technology to control crop pests. So far, USDA has approved commercial use of Granny Smith and Golden Delicious “Arctic” apples, and the company plans to produce Gala and Fuji cultivars in the future. Beyond the questionable utility of an apple that does not brown, are the health and economic risks associated with the apple’s commercial production and use. Some opposing the GE apple have dubbed it the “botox apple” as it can give apples  the appearance of being fresh long after […]

(Beyond Pesticides, February 17, 2015) The Center for Biological Diversity filed a lawsuit in federal court in California February 12 against the U.S. Fish and Wildlife Service (FWS) for failing to ensure that three widely used pesticides ””atrazine, 2,4-D and alachlor”” do not jeopardize the survival of two Bay Area endangered species, the delta smelt and Alameda whipsnake. FWS has yet to act on a request from the U.S. Environmental Protection Agency (EPA) to determine whether measures are needed to protect the delta smelt and Alameda whipsnake from exposure to these pesticides. “These pesticides are known to harm wildlife even in miniscule amounts, so it’s long past time that we start taking commonsense steps to protect endangered species, our water and ourselves,” said Brett Hartl, endangered species policy director at the Center. “Putting off any analysis of the harms caused by pesticides for six years is simply unacceptable, and has set back the recovery of these two species substantially.” Scientific research has shown that atrazine can harm the development of amphibians at exposures of just a few parts per billion, is toxic to fish, reptiles, mammals and birds, and may elevate risks of birth defects in people. Up to 80 […]

(Beyond Pesticides, February 13, 2015) With the U.S. Environmental Protection Agency’s (EPA)  nod to the pesticide industry on expanded uses of the herbicides 2,4-D and glyphosate, environmental groups are charging that the agency violated the Endangered Species Act (ESA).  Repeating a pattern of putting the environment in harm’s way through violations of  federal endangered species  law, a lawsuit filed Friday  documents   EPA’s  failure to consult with the U.S. Fish and Wildlife Service (FWS) regarding the impact of the herbicide on two endangered species —the whooping crane and the Indiana bat— with the recent approval of Dow AgroSciences’ herbicide, Enlist Duo, for use on genetically engineered (GE) crops in six midwestern states. Enlist Duo is an herbicide that incorporates a mix of  glyphosate  and a new formulation of  2,4-D, intended for use on GE Enlist Duo-tolerant corn and soybean crops. Approved for use on GE corn and soybeans that are engineered to withstand repeated applications of the herbicide, the creation of 2,4-D-tolerant crops and EPA’s approval of Enlist Duo is the result of an overuse of glyphosate, an ingredient in Monsanto’s Roundup. The misuse resulted in an infestation of glyphosate-resistant super weeds which can now be legally combatted with the […]

(Beyond Pesticides, February 10, 2015) Scientists at the Universities of Dundee and St. Andrews in Scotland have found evidence confirming that the levels of neonicotinoid (neonic) pesticides bees are likely to encounter in the wild impair the pollinator’s brain cells, resulting in colony declines. Bees and other wild pollinators provide services of over $125 billion globally, but are experiencing widespread and consistent losses that have the potential to increase global malnutrition and disease if not properly addressed. Although countries and regions across the globe have taken action to suspend or restrict the use of neonic pesticides in light of their threat to bees, policymakers in the U.S. continue to delay, impose inadequate changes, or even introduce new bee-toxic chemicals. The recent study, Chronic exposure to neonicotinoids increases neuronal vulnerability to mitochondrial dysfunction in the bumblebee (Bombus terrestris), published in the Journal of the Federation of American Societies for Experimental Biology, finds a mechanistic explanation for previous findings that observed poor navigation and foraging in colonies of bumblebees exposed to neonicotinoids. To do this, researchers exposed bumblebees to doses of the neonics imidacloprid and clothanidin generally expected to be seen in the field (10 nanomoles[nM]/2.1ppb), and measured the amount that accumulated […]

(February 9, 2015, Beyond Pesticides) A report, Monarchs in Peril: Herbicide-Resistant Crops and the Decline of Monarch Butterflies in North America, released by Center for Food Safety (CFS) last week, reveals the devastating  impact of Monsanto’s and the nation’s biggest selling herbicide, Roundup (glyphosate), on the survival  of monarch butterflies. The herbicide is  used to treat  millions of acres of herbicide-tolerant  genetically engineered (GE) crops, eliminating the monarchs’ sole source  of food, milkweed, and approaching  a collapse of their population, which has plummeted over the past 20  years. The report cites findings that  glyphosate use on Roundup Ready  (glyphosate-tolerant) crops has nearly eradicated milkweed around farmland in the monarchs’ vital midwest breeding ground. At the urging of scientists and public interest groups, the U.S. Fish and Wildlife Service (FWS) is currently considering listing the monarch as a threatened species under the Endangered Species Act (ESA). “This report is a wake-up call. This iconic species is on the verge of extinction because of Monsanto’s Roundup Ready crop system,” said Andrew Kimbrell, executive director at Center for Food Safety. “To let the monarch butterfly die out in order to allow Monsanto to sell its signature herbicide for a few more years is […]