(Beyond Pesticides, June 4, 2020) A new, simultaneous chemical identification method has found the presence of the weed killer atrazine and 200+ other hazardous chemicals in hydraulic fracturing (fracking) wastewater or produced water, according to collaborative research published in the Journal of Separation Science by scientists at the University of Toledo (UToledo) and the University of Texas at Arlington. Although produced water is a waste product of fracking, the U.S. Environmental Protection Agency (EPA) allows many states to reuse produced water in agriculture and other industries or dispose of it into waterways. There is serious concern about the safety of produced water and it being a widespread source of pollution. Current disposal and purification practices do not guarantee environmental pollutant’s removal from produced water. This research, “Optimization of thin film solid phase microextraction and data deconvolution methods for accurate characterization of organic compounds in produced water,” highlights the need for comprehensive chemical composition assessment of produced water, whether for reuse or disposal. Currently, EPA waives requirements that chemical companies (e.g., Syngenta in the case of atrazine) monitor for the presence of pesticides in waterways, endangering public health of the environment. Because produced water, whether treated or not, is typically not void of toxic […]

(Beyond Pesticides, June 2, 2020) During the April meeting of the National Organic Standards Board (NOSB), there was near-unanimous sentiment expressed by NOSB members and stakeholders that the failure of the National Organic Program at USDA to act on NOSB recommendations regarding so-called “inert” ingredients hurts organic producers and consumers and the environment. The NOSB has only one alternative left to force USDA action—denying relisting at the Fall meeting. Tell the National Organic Program and USDA Secretary Sonny Perdue to initiate action to begin NOSB review of “inerts” now. Dr. Asa Bradman, who summarized the issue for the NOSB at the Spring 2020 meeting, is an expert in environmental health, and as part of his day job, leads studies focusing on pesticides, flame retardants, metals, emerging pollutants, VOCs, indoor air quality and other contaminants. As he said at the meeting, “These are often active ingredients.” In fact, the ingredients not listed on a label of a pesticide product—which are not fully reviewed for their adverse effects—may be the most toxic chemicals in the formulation. Recent research, Toxicity of formulants and heavy metals in glyphosate-based herbicides and other pesticides (Toxicology Reports 5, 2018), by Defarge, de Vendômois, and Séralini demonstrates the need to […]

(Beyond Pesticides, June 1, 2020) The President issued another executive order, on May 7, that continues his administration’s dissembling on matters that affect the well-being of everyday Americans. This EO (executive order) purports to “promote American seafood competitiveness and economic growth.” The reality, as the Center for American Progress reports, is that the “bulk of the Trump administration’s new executive order sets up a structure for permitting of offshore aquaculture in federal waters with short timelines and few environmental safeguards.” This EO will further erode regulations that have governed the operation of so-called “fish farms,” and open enormous marine areas to exploitation by this industry. Beyond Pesticides has argued for more-protective regulation of the aquaculture industry, considering the variety of pesticides and chemical inputs it uses, and the impacts on local ecosystems. The U.S. Department of Agriculture (USDA) defines aquaculture as any “farming of aquatic organisms, including baitfish, crustaceans, food fish, mollusks, ornamental fish, sport or game fish, and other aquaculture products. Farming involves some form of intervention in the rearing process, such as seeding, stocking, feeding, protection from predators, etc. Fish, crustaceans, mollusks, and other aquatic products caught or harvested by the public from non-controlled waters or beds are considered […]

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

(Beyond Pesticides, May 22, 2020) For years, USDA has been looking the other way as giant corporate agribusinesses, primarily producing conventional eggs and poultry, have squeezed family-scale farmers out of the market and misled and defrauded consumers. Due to a lawsuit challenging the Trump administration on the scuttling of new rules that would make it harder for factory farms to qualify for organic status, USDA is seeking input on what was previously an error-filled and biased economic assessment of the rulemaking. Please sign the letter by noon on Tuesday, May 26, to include your voice in our response to the official proceedings. If you would prefer to write your own custom comment you can submit it on Regulations.gov. Letter to National Organic Program (Jenny Tucker, Ph.D. To the National Organic Program: Please include my comment below in evaluating the economic analysis report pursuant to the Organic Livestock and Poultry Practices rulemaking. Docket number: AMS-NOP-20-0037 Both the current and previous OLPP analyses include the following misstatements and omissions: It is a misconception to refer to, and judge, the economic impacts of the OLPP as if the requirement for outdoor access was a new and onerous regulation. In fact, from the beginning of the USDA organic […]

(Beyond Pesticides, May 19, 2020) The California Department of Food and Agriculture (CDFA) is taking public comments on a proposal to establish statewide comparable-to-organic standards for cannabis production. Although cannabis remains illegal at the federal level, and thus cannot be labeled with the U.S. Department of Agriculture (USDA) certified organic seal, there is no prohibition on a state-specific program that follows federal organic requirements, but does not use the word “organic.” While such a program has the potential to provide another level of protection for medical patients, questions and concerns remain over the allowance of certain products, and the impact the certifying scheme may have on the future trajectory of the cannabis production industry. Under the Medicinal and Adult-Use Cannabis Regulation Safety Act, passed in 2017 after the success of Proposition 64 by California voters, state agencies were tasked with establishing a state-level program to certify cannabis to the standards set out by USDA’s National Organic Program (NOP). CDFA is required to finalize this program for cannabis production by the start of 2021, while the California Department of Public Health will create a separate program to certify manufactured cannabis products. As outlined by CFDA, cannabis would be certified through third-party […]

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

(Beyond Pesticides, May 15, 2020) New research out of Japan’s Chiba University suggests that exposure to glyphosate, the active ingredient in the most commonly used pesticide worldwide (Roundup), may be a risk factor in the development of Parkinson’s Disease. The ubiquity of glyphosate use in agriculture — which leaves residues of the toxic chemical in food — may mean that exposures to it represent a significant risk factor for the disease. Glyphosate is already implicated or proved in the development of numerous health anomalies, including cancer. Beyond Pesticides recognizes that pesticides play a variety of roles in causing or exacerbating negative health outcomes, including Parkinson’s Disease (PD). Transitioning pest management — in agriculture, land management, and household and personal care contexts — to nontoxic and organic approaches is the critical step away from bathing humans and the Earth in harmful chemicals. The researchers in this subject study, out of the Chiba University Center for Forensic Mental Health’s Division of Clinical Neuroscience, sought to investigate whether exposures to glyphosate could impact dopaminergic neurotoxicity in the brains of mice. They found that exposures to glyphosate in adult mice intensified a type of neurotoxicity associated with PD. [The abstract for the research paper, titled […]

(Beyond Pesticides, May 14, 2020) Four banned organochlorine pesticides (OCP) are present in over 60% of a cohort of reproductive-age, black women in Detroit, according to a study published in Environmental Research by Boston University School of Public Health (BUSPH). OCPs are lipophilic (fat combining/dissolving), environmentally steadfast chemicals linked to harmful health effects. This study stresses the importance of monitoring pesticide accumulation, particularly regarding environmentally persistent chemicals and their metabolization via indirect exposure routes. Lead author Olivia Orta, Ph.D., a postdoctoral research associate in the Department of Epidemiology at BUSPH, highlights the significance of water monitoring—especially in light of historically disproportionately high hazards for people of color (e.g., Flint, Michigan)—and testing sources prone to OCP contamination. She remarks, “The sources that we identified as potential OCP correlates should be tested for pesticide contamination,[…] especially drinking water.” Environmental contaminants, like organochlorine pesticides (OCP), can persist in the environment decades after use stops, as OCPs have greater chemical stability and gradual attenuation. Minority populations are at higher exposure risk of environmental contaminants (i.e., pesticide) exposure that can catalyze adverse health and birth effects, especially in metropolitan areas. Although black women endure higher body burdens than other U.S. populations, there remains a lack of research surrounding the association. Boston University researchers enrolled […]

(Beyond Pesticides, May 8, 2020) At the height of Covid-19 impacts in the Northeast U.S., Massachusetts Governor Charlie Baker (R) and Lieutenant Governor Karyn Polito (R) filed emergency legislation at the Boston State House that would, according to their April 16 press release, “help the Commonwealth more effectively combat diseases transmitted by mosquitoes, including arboviruses like Eastern Equine Encephalitis (EEE) and West Nile Virus (WNV), by authorizing a coordinated, proactive, statewide approach to mosquito control activities.” Protecting the public from such diseases is an important public health mission. However, the Governor’s bill, H.4650, represents an alarming “over-reach” that would give unitary authority to the State Reclamation and Mosquito Control Board (SRMCB) to conduct mosquito control activities, including ineffective and toxic spraying, with virtually no effective oversight or transparency. Beyond Pesticides opposes this bill, whose passage would enable use of pesticides that can have respiratory and immune impacts — increasing health risks for everyone, but especially for the many people already at higher risk from Covid-19, despite the availability of ecological management approaches that eliminate the need for toxic chemicals. H.4650, An Act to mitigate arbovirus in the Commonwealth — was promulgated in response to a Massachusetts Department of Public Health […]

(Beyond Pesticides, May 7, 2020) On April 22, 2020, the Ninth Circuit U.S. Court of Appeals granted the U.S. Environmental Protection Agency (EPA) 90 days to respond to Natural Resources Defense Council’s (NRDC) petition requesting cancellation of tetrachlorvinphos (TCVP), a toxic organophosphate pesticide in pet products. The order followed the Ninth Circuit’s decision to grant NRDC’s petition for a writ of mandamus (a court’s order requiring a lower court or public authority to perform its statutory duty) as EPA withheld action to fulfill NRDC’s judicial review of TCVP, for over a decade. A favorable ruling on NRDC’s mandamus petition can influence other petitioners that hope to coerce agency action, especially when public health is at risk. The court states, “Repeatedly, the EPA has kicked the can down the road and betrayed its prior assurances of timely action, even as it has acknowledged that the pesticide poses widespread, serious risks to the neurodevelopmental health of children.” NRDC petitioned EPA to cancel TCVP pesticide registration under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) in April 2009, after studies indicated humans absorb TCVP through contact with pesticide-treated pet products. EPA failed to respond to the initial petition after five years, and NRDC filed a 2014 mandamus requiring […]

(Beyond Pesticides, May 6, 2020) The Trump Administration announced late last month that it is waiving a requirement that multinational chemical company Syngenta-Chemchina continue to monitor Midwest waterways for the presence of the weedkiller atrazine throughout 2020. While rationalized by the Administration as “due to the unanticipated impact of Covid-19,” the move will instead put residents health at increased risk. Atrazine is one of 78 pesticides that has been linked to the development of respiratory ailments like wheeze. “The public will now have no idea whether dangerous levels of atrazine are reaching rivers and streams throughout the Midwest. That’s absurd and reckless,” said Nathan Donley, PhD a senior scientist with the Center for Biological Diversity. “Syngenta should suspend the sale and use of this extremely toxic pesticide until it can safely ensure it’s not polluting Corn Belt waterways.” Syngenta, which merged with state-owned China Nation Chemical Corporation (Chemchina) in 2016, has been bound by EPA to monitor Midwestern waterways since a 2004 review by the agency. This is because atrazine is a potent groundwater contaminant. Just two years ago, an analysis by the Environmental Working Group found atrazine to be exceeding legal limits in drinking water for many Midwestern states. […]

(Beyond Pesticides, May 6, 2020) The coronavirus pandemic highlights pre-existing cracks in social safety nets and environmental regulation. Pollutants, such as respiratory and immune-suppressing toxic pesticides, exacerbate the risk factors for people already vulnerable to Covid-19. Decades of environmental racism and other health factors are contributing to the devastating fact that in the U.S. black and brown communities are disproportionately impacted by this crisis. These same communities make up the bulk of frontline, essential workers; grocery store employees, security staff at hospitals, bus drivers, farmworkers, and others are keeping our country going through the pandemic. Government and corporation responses have been insufficient to help these individuals. As a society, we need to better support workers who are essential, and not expendable. Farmworkers, the backbone of our entire food system, are at extremely high risk of COVID-19 as well as pesticide poisoning due to crowded working conditions and lack of personal protective equipment. As agribusinesses ask farmworkers to work for less pay in the midst of the pandemic, they need your help. Giving Tuesday Now is a national donation campaign responding to the pandemic. While Giving Tuesday traditionally encourages donations to non-profits in November, today there is a push to encourage […]

(Beyond Pesticides, May 1, 2020) As the globe settles in for a long summer of social distancing to prevent the spread of COVID-19, experts warn that concentrated animal feeding operations (CAFOs), more commonly referred to as “factory farms,” are setting the table for the next pandemic. Crowded conditions and prophylactic use of antibiotics, scientists say, are creating an environment ripe for viruses and bacteria to evolve and jump from animal to human populations. The Food and Agriculture Organization of the United Nations said back in 2013, “Livestock health is the weakest link in our global health chain.” Alternatively, organic principles offer an existing federal guideline for ecologically and environmentally viable conditions for agriculture. Michael Greger, M.D., Ph.D., author of Bird Flu: A Virus of Our Own Hatching, explains, “When we overcrowd animals by the thousands, in cramped football-field-size sheds, to lie beak to beak or snout to snout, and there’s stress crippling their immune systems, and there’s ammonia from the decomposing waste burning their lungs, and there’s a lack of fresh air and sunlight — put all these factors together and you have a perfect-storm environment for the emergence and spread of disease.” Dr. Greger notes that the spread of […]

(Beyond Pesticides, April 30, 2020) Chemical-intensive farming of crops for animal fodder powers the global market for highly hazardous pesticides (HHPs), according to data analyzed by Unearthed, and the Swiss NGO Public Eye. Animal fodder production not only intensifies global pollution, but it also increases pesticide exposure and degrades human, animal, and environmental health. This data analysis supports advocates advancing pesticide policies to eliminate HHPs by identifying which toxic chemicals lead global pesticide sales. However, it will take more than eliminating the worst chemicals to address the impending biodiversity collapse and the climate crisis, according to experts who point to the need for an urgent shift to organic land and agricultural management practices. United Nations’ (UN) special rapporteur on toxic substances and human rights, Baskut Tuncak, says, “There is nothing sustainable about the widespread use of highly hazardous pesticides for agriculture. Whether they poison workers, extinguish biodiversity, persist in the environment, or accumulate in a mother’s breast milk, these are unsustainable, cannot be used safely, and should have been phased out of use long ago.”  Unearthed and Public Eye investigated over $23 billion in global pesticide market sales to determine the proportion of pesticides considered highly hazardous by the Pesticide Action Network’s […]

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

(Beyond Pesticides, April 23, 2020) Pesticide spray drift from adjacent farmlands expose butterfly larvae to lethal pesticide concentrations, according to research published in Environmental Toxicology and Chemistry by Iowa State University (ISU). Lack of previous experimental pesticide toxicity data makes it unclear as to what degree insecticides impact monarch butterfly (Danaus plexippus) productivity in milkweed (Asclepias spp.) habitats near pesticide-treated pasture. This study adds weight to the idea that pesticides are playing a role in the ongoing decline of this iconic butterfly, as researchers find insecticide drift from adjacent fields to be strongly associated with larval mortality. Future monarch butterfly conservation efforts should consider risks stemming from pesticide exposure when developing butterfly rehabilitation efforts, according to advocates. As co-author Niranjana Krishnan (ISU graduate student) states, “In order to make the best decisions about how and where to plant milkweed, we first need to find basic toxicity and exposure data.”  ISU researchers established monarch butterfly colonies by collecting larvae from roadside milkweeds, which they then reared in the laboratory for incubation. To analyze the relative toxicity of various insecticides on monarch butterflies, researchers applied normal field-application rates of each pesticide at different larval development stages. Scientists used a bioassay to measure the […]

In 1962, Rachel Carson said we stood at a crossroads: “The road we have long been traveling is deceptively easy, a smooth superhighway on which we progress with great speed, but at its end lies disaster. The other fork of the road — the one less traveled by — offers our last, our only chance to reach a destination that assures the preservation of the earth.” Eight years later, on April 22, 1970, the first Earth Day encouraged collective action for conservation. Now, in the midst of a pandemic and cascading environmental crises (arguably, down the road of disaster), forging a new path toward restoration will take courage and imagination. This Earth Day, Beyond Pesticides is putting forth a toolkit to abandon half measures and forge ahead with an organic approach for repairing human health and the environment. LISTEN TO SCIENCE Biodiversity is plummeting worldwide. The climate crisis looms even as COVID-19 grabs headlines. Environmental pollution is a predictor of coronavirus death. Never has it been more obvious that the global community is interconnected, and enforcing preventative measures is critical before it is too late. Meanwhile, the Trump Administration’s Environmental Protection Agency (EPA) ignores science, moving ahead with deregulation to […]

P-22 is being treated for mange; blood tests found anti-coagulant rodenticides, commonly known as rat poison. (Beyond Pesticides, April 21, 2020) Last week, the California Fish and Game Commission voted unanimously to give mountain lion populations in certain parts of the state temporary protective status, and initiate a year-long study to consider permanent safeguards. Mountain lions in California are under considerable threat from a range of issues, including inbreeding, human developments, and the use of hazardous rodenticides. “There’s an extraordinary urgency for action to preserve this population,” said Commissioner Samantha Murray prior to the unanimous vote, according to the OC Register. According to a study published last year in the journal Ecological Applications, mountain lion populations in Southern California’s Santa Ana and Santa Monica Mountains are at risk of local extinction within 50 years without intervention. Highways and other man-made structures have hemmed in the cougars, resulting in inbreeding that threatens genetic diversity and can result in sterile offspring.  Although specific actions under the new status are not guaranteed, it will force changes within California executive agencies. “For Caltrans, this could include building wildlife crossings over or under existing freeways or as part of freeway expansion projects,” J.P. Rose, staff […]

(Beyond Pesticides, April 20, 2020) As USDA takes public comments on its updated dietary guidelines, it important that sustainable, regenerative organic food production practices are an integral part. Since 1990, Congress has required an every-five-years review of its Dietary Guidelines — recommendations intended to promote public health and prevent chronic diseases. The next review and a draft updated version, the 2020–2025 Dietary Guidelines for Americans, is currently underway. USDA says that the dietary guidelines provide “information that helps Americans make healthy choices for themselves and their families.” In order to make healthy food choices, the guidelines must go beyond the traditional parameters to include how the food is produced. How food is produced affects the health of Americans not only as a result of the nutritional quality of the food, but also due to environmental contamination. Sign the petition to USDA and send a letter to Congress. Tell them that organic food must be emphasized in new dietary guidelines. Although research on the nutritional density of organic produce is equivocal, showing some higher levels of antioxidants, results are decidedly clear for animal products. Pastured organic animal products—including beef, lamb, pork, dairy, poultry, and eggs—have been shown to be superior to that of products of […]

(Beyond Pesticides, April 17, 2020) As the novel coronavirus pandemic upends much of human activity, some governments are acting to loosen environmental regulations — purportedly, in the interests of public health in the face of Covid-19 threats, and/or in deference to economic concerns of certain industrial sectors. There has been little analysis, to date, of what the “on the ground” impacts of these relaxed rules may be, but news out of Scotland illustrates some kinds of concerns critics and advocates have about such loosening of regulations. The Scottish Environment Protection Agency (SEPA) has issued new, temporary rules that allow some salmon farms both to ignore newly established limits on the amount of emamectin, an insecticide used to control sea lice that plague the salmon, and to boost use of azamethiphos, another insecticide used against the lice, beyond previous 24-hour limits. SEPA says the relaxed rules will endure only as long as the Covid-19 “lockdown” remains in place (perhaps the end of June), and apply only to new or expanding enterprises, which to date total approximately 14 of the country’s 200+ salmon farms. The farmed salmon industry represents a huge domestic and export commodity worth approximately $2.5 billion annually. In addition […]

(Beyond Pesticides, April 14, 2020) An op-ed in the New York Times asks, “What Happens if America’s 2.5 Million Farmworkers Get Sick?” Without those farmworkers, the year-round supply of fresh fruits and vegetables that we take for granted would be impossible. The supply chain of those vital foods starts with the workers who plant, cultivate, and harvest them. Our society and everyone living in the U.S. depend on farmworkers. Tell Congress to provide essential benefits to essential farmworkers. But farmworkers are at high risk from the coronavirus (COVID-19) pandemic. Living in crowded conditions, social distancing is impossible for them. They have little access to health care. Washing hands is often impossible in the field. With children home from school, they have additional childcare costs to pay with their low wages. They also have increased costs from using private transportation to avoid crowded buses. And many farmworkers are exposed to respiratory hazards like pesticides and fungal spores that make them more susceptible to the coronavirus. As the medical demand for personal protective equipment (PPE) increases, farmworkers are being faced with potential shortages of masks, gloves, and suits. Last month, a group of Washington farmworkers walked off a worksite because their employer was not offering sufficient […]

(Beyond Pesticides, April 13, 2020) Since 1990, Congress has required an every-five-years review of its Dietary Guidelines — recommendations that are supposed, minimally, to promote public health and prevent chronic diseases. The next review and a draft updated iteration, the 2020–2025 Dietary Guidelines for Americans, are currently underway. The Union of Concerned Scientists (and several colleagues) have examined recent studies on dietary patterns and sustainability; their analysis reveals that the current federal guidelines on diet are unlikely to support sustainability of the food system in the long-term. Beyond Pesticides concurs, and maintains that a transition to sustainable, organic, regenerative agriculture is the path to both improved human health and long-term sustainability of the natural world essential to life. The Union of Concerned Scientists’ (UCS’s) report — In Support of Sustainable Eating: Why U.S. Dietary Guidelines Should Prioritize Healthy People and a Healthy Planet — identifies this next version of the federal guidelines as a critical opportunity to shift the direction of the U.S. food and agricultural system toward far greater sustainability. UCS asserts that such a shift is beyond due: the food system in the U.S. has huge environmental impacts on pollution, use of chemical pesticides, biodiversity, and emissions that significantly […]